Re: OT: Wills and a Public Trustee
Apud Kevin Gowen <kgowen@nogmailspam.com> (fj.life.in-japan) hoc legimus:
>jwb@csse.monash.edu.au wrote:
>> Curiously I was just reading a short story by 宮本輝 which
>> involved a handwritten unwitnessed will. Seems it'd be honoured.
>I used holographs simply as an example of ways wills can be valid in one
>jurisdiction but not another. I wasn't talking about whether holographs
>are kosher under Japanese law.
>My guess is that the short story was fictional, though.
Most short stories are 8-)}
>>> Another wrinkle is that Australia is an Anglo-American common law
>>> system, while Japan is a quasi-civil law system. For example, there is
>>> no equivalent to the 公証人 in Australia.
>>
>> Thank goodness. (I see Prodi is trying to get rid of them in
>> Italy, and striking heavy weather.)
>Hmm. I became a fan of the civil law notary once I learned about it. I
>plan to take the notary exam here once I'm eligible to sit for it. (five
>years of practice in Florida)
Well, in the case of Italy it's not so much a matter of getting rid of
them as reducing their role to what is necessary and appropriate. At
present even the sale of second-hand motor bikes needs to be notarized.
A friend of ours in Paris had an interesting notary problem. Her
apartment, which had been vacant while she was working away from
Paris, turned out to be occupied by a person who was renting it
from someone who'd broken in, then had the locks changed. The trouble
was that the occupant had a duly notarized rental contract. In other
words a notary had signed off either without doing the checks he/she
is required to do, or was corrupt and doing it for a bribe.
Either way, it was a hellava job to get the "tenant" out as the
authorities didn't want to move against someone who had a notarized
contract. Our friend, in effect, had to prove that the "contact"
was bogus because, prima facie, if it was notarized it was legal.
--
Jim Breen http://www.csse.monash.edu.au/~jwb/
Clayton School of Information Technology,
Monash University, VIC 3800, Australia
ジム・ブリーン@モナシュ大学
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