Proprietatea în dreptul român și modelul său francez: o evoluție în contratimp

The French revolutionary model of ownership is presented in comparison with his Romanian replica. Despite the identity of the legal formulas used, as the Romanian Civil Code of 1864 is, in its essence, just a translation of The Napoleon Code, the concept of ownership is reflected in the legal culture of the two countries, strongly influenced by the socio-political context of each of them. A certain syncope can be observed in the evolution of ownership traits, in Romanian law compared to its French model. Strangely, the current Romanian notion of ownership right is closer to that of the Napoleon Code than the current figure of its French model.