n Acta Juridica - Comparing the and the South African trust




This article compares the South African trust and the . The article will firstly involve a concise analysis of the theories on the possible predecessors of the while providing a historical contextualisation of the and the trust. Secondly, a comparison will be made between the South African trust on the one hand, and the on the other hand, the latter being one of the theories advanced as a possible source of the use. This comparison, it is hoped, will pave the way for further comparative research regarding the as a means of advancing the development of South African trust law.


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