COMPARATIVE ANALYSIS OF LAND REGISTRIES

Abstract

The paper focuses on the main differences between the common law systems and continental systems (in particular the Serbian system) in respect of the conveyance of titles and other interests and land registries. Common law systems recognise the conveyance of title by the delivery of deeds or any other instruments, unlike the Serbian system which requires the registration of title in the land registry. The structure and effects of land registries are different between the two systems, whereby the Serbian system provides better protection of future purchaser and of current holders of titles and other interests. Despite those differences there are significant efforts to introduce the internet access to land registries into both systems.