Eva Micheler analyses the English, German and Austrian law of
securities, addressing the rules governing transfers of securities,
including unauthorised transfers, equities arising out of defective
issues and the holding of securities through intermediaries.
The book presents an account of the current English, German
and Austrian legal regimes. It has been written with a view to
explaining the German and Austrian regime to readers with a
common law background and to explaining the English regime
to readers with a civil law background.
The book also aims to determine whether globalisation will
cause the two different approaches to converge. It concludes that
the respective rules in all three jurisdictions have historically
evolved consistently with incumbent legal doctrine. This pattern
of change is likely to continue. Convergence will occur on a
functional rather than on a doctrinal level. Moreover recent
reform initiatives advanced by the UNIDROIT and the EU will
lead to functional rather than doctrinal convergence.