A comparative study of devotion in iran's rights with trusts in england law

Abstract

The legal system of Islam, devotion means that some property is dedicated to God and similarly there is a "Caman La trusts" in the legal system. In both legal systems, and maintain the property owner has good intentions for good intentions and good practice and preservation of their wealth for future generations and keep them everlasting but pause and review the implementation of the establishment of these two institutions, each with attributes, constraints manipulation owner of the establishment, the powers of the trustee and the trust in the transfer of ownership or interest, governance, and oversight of endowment and trust funds. Based on the legal rules governing the regulation of the devotion, the devotion is limited and there is no possibility of selling and making money are devoted to interest alone. The comparative trust is essential suggestions are given to change laws which this paper deals with a comparative study of these two entities. © 2014 AENSI Publisher All rights reserved.