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    Review of European and Comparative Law

    Review of European and Comparative Law

    JournalISSN N/AeISSN 2545-384X中科院 社会学 4区

    年发文量

    研究主题

    论文(412)

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    1When the EU AI Act Travels: Legal Transplantability and Modular Adaptation in Third-Country AI Governance
    Van Thanh Hoang, Ngoc Mai Nguyen

    This article examines the extent to which the EU AI Act can function as a model for AI governance beyond the European Union. It argues that regulatory influence should not be equated with successful legal transplantation. While the Act has quickly become a reference point for lawmakers and regulators outside Europe, its elements vary significantly in portability across legal systems. The article develops and applies a four-part framework for assessing legal transplantability, focusing on normative transplantability, institutional transplantability, market transplantability, and rights-operability. It uses selected third-country examples, including Japan, Singapore, the United Kingdom, and Brazil, not as an exhaustive survey, but as comparative tests of how different regulatory environments absorb, translate, or resist elements of the EU model. On that basis, the article distinguishes between elements of the Act that are comparatively more portable, such as risk-based classification, baseline transparency duties, documentation logic, and incremental governance tools, and those that resist transplantation more strongly, especially enforcement density, technical conformity infrastructures, and the rights-operability that makes fundamental-rights commitments actionable in practice. The article concludes that the EU AI Act travels most plausibly not as a complete statutory template, but as a modular regulatory architecture. Its comparative value for third countries lies less in wholesale replication than in selective adaptation sequenced to institutional capacity and regulatory readiness.

    2026
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    2The New Law on Civil Confiscation in the Republic of North Macedonia
    Nina Madjovska Naumovska

    Confiscation, as a criminal law measure, plays a significant role within the legal framework of the Republic of North Macedonia, although it does not represent a novelty in the national legislation. The 2004 legal reforms formally introduced confiscation as a mechanism aimed not at punishment but at restoring legal equity by depriving individuals of assets unlawfully acquired through criminal activity. The legal framework distinguishes between in rem confiscation regulated under civil law and in personam confiscation applied within the scope of criminal law. The adoption of the Law on Confiscation of Property in Civil Proceedings introduced the possibility of confiscating property without a final criminal conviction, thereby broadening the state’s capacity to target assets reasonably suspected of illicit origin. This development raises important questions as to procedural safeguards and legal certainty, particularly in relation to the rule of law and the protection of individual rights. The paper examines the normative and procedural aspects of both forms of confiscation, their implementation in practice, and the underlying reasons for their limited application in judicial proceedings.

    2026
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    3William Nikolakis, Ed., Land Rights Now: Global Voices on Indigenous Peoples and Land Justice , Cambridge: Cambridge University Press, 2025, Pp. 364
    Marcin Jerzy Konarski
    2026
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    4Definitional Consistency in Nuclear Law: Polish Atomic Law, Directive 2013/59/euratom and the Limits of Legislative Drafting
    Ewa Katarzyna Czech, Robert Bobkier,Lyazzat Sembiyeva

    This paper conducts an audit of the definitional layer of the Polish Atomic Law through the lens of legislative drafting principles and the terminology of the Directive 2013/59/Euratom. It demonstrates that the unusually extensive glossary of the Atomic Law is structurally fragmented across the general definitions in Article 3 and multiple chapter-specific glossaries, including cases where technical concepts are defined only for specified chapters of this Act while operating throughout its normative framework. The analysis further shows that parallel “general” and “special” definitions within a single statute may destabilize interpretative reconstruction. The article also identifies a multilingual defect in the Polish-language version of the Directive concerning the clearance/exemption distinction, and highlights additional scope-sensitive divergences in Polish transposition (natural radiation; dose limit). These findings underscore the regulatory costs of definitional inconsistency for legal certainty and the uniform application of Euratom standards.

    2026
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    5Historical Foundations and Post-Socialist Reconstruction of the Latin-type Notariat in the Successor States of Former Yugoslavia
    Attila Dudás, Emma Király-Szitás

    This study examines the historical foundations of the Latin-type notariat in the successor states of the former Yugoslavia. In order to understand the contemporary system of notarial institutions in the Western Balkans, the layered historical interaction of different legal traditions, interwar harmonization efforts, and socialist abolition should be analyzed. The paper aims to present the development of the Latin-type notariat through two decisive historical phases: the pre-1945 coexistence of Austro-Hungarian and Ottoman legal models together with the partial and uneven implementation of the 1930 Notaries Act, and the structural rupture caused by the socialist dismantling of the notarial profession. Through a historical-comparative methodological approach, the study demonstrates that the evolution of the Latin-type notariat in the region was a lengthy process of institutional development under the influence of legal particularism and disrupted professional continuity. These findings provide the analytical foundation for a subsequent comparative evaluation of contemporary notarial systems in the region.

    2026
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    立即登录,查看全部 412 篇论文

    高被引作者

    作者引用发文
    Maciej Nyka412
    Piotr Radziewicz132
    Krzysztof Orzeszyna92
    Krzysztof Mikolajczuk81
    Robert Tabaszewski82
    Małgorzata Polkowska71
    dana dobric61
    Izabela Wróbel62
    Karol Dobrzeniecki51
    Anna Kapala51

    高产作者

    作者引用发文
    Elzbieta Zebek34
    Monika Augustyniak34
    Marcin Konarski14
    Marcin Burzec24
    Agnieszka Żywicka43
    Ena Kazic23
    grazyna szpor23
    Paweł Marcin Zdanikowski13
    Vincent Glerum23
    Rafał Czachor12

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