On the Issue of Obtaining Bill Right from the Perspective of Comparative Law

In bill circulation,many factors hinder bill bearer's proper integrity of bill right.Such systems as independent principle of bill act,human's defense limitation and the good intentions of obtaining bills,etc.,should,on the one hand,protect the bill right of the bill bearer with good intentions;On the other hand,it should treat the litigant in a fair and rational way.With the reference of international bill law as well as bill legislation in U.K.,U.S.and France,it is the first choice of future bill legislation to revise the flaws of bill right provisions and improve the bill right system in China.