海峡两岸非完全行为能力人致害责任比较研究

A Comparative Study on Liability of Damage Causing by Persons Living Across the Strait and Having Incomplete Capacity for Civil Conduct

本文主要从责任类型、归责原则、责任主体和责任构成要件四方面对海峡两岸有关无民事行为能力人、限制民事行为能力人致人损害赔偿法律制度进行了比较 ,分析了两岸在这方面规定的差异与原因 ,并提出了自己的一些见解。

With respect to the liability of damage causing by persons who live on both sides of Taiwan Strait and have no or limited capacity for civil conduct, the legal system on the compensation is studied comparatively. The comparative study is made from such aspects as type of liability, doctrine of liability fixation, person liable, important conditions making up liability.