未成年人缔约能力制度比较研究

Compartive Study about the Systems of Minor's Conracting Capacity

各国民法典或者合同法对未成年人的缔约能力都作了规定,这些规定在总体上既体现了对未成年人利益的特殊保护,又注重维护交易安全和善意成年人的利益。各国立法对未成年人缔约能力的规定也呈现了各自不同的特点,值得中国立法借鉴。

Minor's Contracting Capacity has been strpulated by the civil code and contract law in different countries. These stipulations in general embody special protection of minor's interests and pay attention to defending trading safety and the interests of adults in good faith. The legistilation in other countries has it's own character is this in stipulating minor's contracting capacity. And this is worth China's reference in it's legistilation.