A COMPARATIVE ANALYSIS OF THE NOTARY INSTITUTION OF THE ROMANO-GERMANIC AND ANGLO-SAXON LEGAL FAMILIES
Аннотация
The public notary is, in principle, a public institution that certifies transactions and gives legal effect to various documents. However, is the institution of the public notary treated equally in different states? The article is devoted to a comparative legal analysis of the institution of notaries of some developed countries of the Romano-Germanic (continental) and Anglo-Saxon legal families, including the Republic of Uzbekistan. The author drew a parallel with the legal phenomena and significant differences of the institute of notaries of such countries as the Republic of Uzbekistan, the United States, Great Britain, Ireland, Germany, France, and Belgium. The article analyzes the current situation of the notary in the above-mentioned countries, focusing on differences and similarities in law enforcement practice. The author applied both empirical (comparison) and theoretical (analysis) research methods in order to maximize the study of aspects and phenomena of the institution of notaries. In the course of the study, a number of drawbacks and specific features of the notarial system of each states were identified. The considered analysis and research could be applied to improve the institution of notaries, the implementation of law enforcement practices and the elimination of deficiencies that may hinder the development of this phenomenon as an independent body in the legal sphere of activity.