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   comparison of dhimmah and asset in french jurisprudence and law  
   
نویسنده ranjbar abdollah ,sadat-hosseini hossein ,zolfaghar mehdi
منبع international journal of multicultural and multireligious understanding - 2020 - دوره : 7 - شماره : 7 - صفحه:129 -142
چکیده    Reference of jurisprudential texts to religion brings to mind the religious right and the obligationto resemble with divisions of law in france. in the legal system of islam, dhimmah (treaty or obligation)have been extensively used along ages and in different fields. on the contrary, in the classical law andfrench law, the title patrimoine (asset or property) is used throughout the commitments. in the religiouslaw, a person who is called a creditor or promisee has direct rights over another person who is calleddebtor or promisor. since debt is directly related to individuals’ obligations, so to identify exact meaningand concept of religious or individual right, it is necessary to examine its execution which is the verydhimmah in jurisprudence or the property and obligation mentioned by arab and french lawyers. in spiteof the similarities between these two terms, there is no comparable capability between the dhimmah andthe asset; for the term dhimma is not compatible with the term patrimoine (asset); hence, in this article,these two terms are to be conceptualized and compared.
کلیدواژه dhimmah (obligation) ,property ,religious right ,liability
آدرس azad university of damghan, iran, azad university of damghan, iran, azad university of damghan, iran
پست الکترونیکی mahdizolfaghari2010@gmail.com
 
     
   
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