Property in securities

Eva Micheler analyses the English, German and Austrian law ofsecurities, addressing the rules governing transfers of securities,including unauthorised transfers, equities arising out of defectiveissues and the holding of securities through intermediaries.The book presents an account of the current English, Germanand Austrian legal regimes. It has been written with a view toexplaining the German and Austrian regime to readers with acommon law background and to explaining the English regimeto readers with a civil law background.The book also aims to determine whether globalisation willcause the two different approaches to converge. It concludes thatthe respective rules in all three jurisdictions have historicallyevolved consistently with incumbent legal doctrine. This patternof change is likely to continue. Convergence will occur on afunctional rather than on a doctrinal level. Moreover recentreform initiatives advanced by the UNIDROIT and the EU willlead to functional rather than doctrinal convergence.