An assignment of movables can give rise to various problems. This chapter will focus on trying to determine the legal system according to which such matters should be resolved.1 We are not concerned here with what are usually called general assignments, under which, on the occasion of marriage, death and bankruptcy, the entirety of a person’s property may pass to another. Our inquiry is confined to particular assignments inter vivos of isolated or individual movables, of which the commonest examples are sales, gifts, mortgages and pledges. Further, the present...
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