Comparative analysis of the institution "abuse of right" in Russia and similar institute USA, Germany and France

The relevance of comparative legal analysis of the institution of "abuse of right" of Russia and Germany, France and the United States, at first, connected with the interest from both theorists and practitioners of law in the area of comparative law. This problem is highly relevant in today's in Russia, because this institution in Russia is not developed and foreign experience is very important for Russia in this area. This is evidenced by the large number of monographs. However, comparative analyses require further serious study and analysis. Many aspects of comparative law are debatable and have no clear interpretation.