一、引言在前苏联领土上一系列独立国家的形成以及新兴的民主政权向市场经济的转变促使这些国家国内立法迅速发展。对此,民法也不例外。但是同时,一个不容忽视的事实常常是,虽然这一进程是必要的且大体说来也是有 I. INTRODUCTION The formation of a series of independent states in the territory of the former Soviet Union and the transition of a newly emerging democratic regime to a market economy have prompted the rapid development of domestic legislation in these countries. In this regard, civil law is no exception. At the same time, however, one fact that can not be ignored is often that while this process is necessary and generally speaking