DOI: 10.7256/2454-0706.2016.3.18311

Abstract: This article explores the issues of alimony for adult disabled children in need from the comparative legal perspective. In the comparative key the author examines the subject composition of parties, as well as conditions for provision of alimony (disability, need). This work considers the normative material and legal precedent of various legal families on the example of such states and state constructs as Germany, Russia, France, California (U. S.), Morocco, and Algeria. The author highlights the regularities of the institution of alimony that is common for all countries, as well as the specificity of each of them. The alimony institution for disabled adult dependence in need carries a different specificity in different legal families. These peculiarities pertain to both, the subject composition of alimony obligations, and the conditions under which the alimony payer and alimony recipient acquire mutual rights and responsibilities within the framework of alimony obligations. The author makes the recommendations for improving the Russian legislation in light of the examples of the foreign law.

DOI: 10.7256/2454-0706.2016.3.42927

Abstract: This article explores the issues of alimony for adult disabled children in need from the comparative legal perspective. In the comparative key the author examines the subject composition of parties, as well as conditions for provision of alimony (disability, need). This work considers the normative material and legal precedent of various legal families on the example of such states and state constructs as Germany, Russia, France, California (U. S.), Morocco, and Algeria. The author highlights the regularities of the institution of alimony that is common for all countries, as well as the specificity of each of them. The alimony institution for disabled adult dependence in need carries a different specificity in different legal families. These peculiarities pertain to both, the subject composition of alimony obligations, and the conditions under which the alimony payer and alimony recipient acquire mutual rights and responsibilities within the framework of alimony obligations. The author makes the recommendations for improving the Russian legislation in light of the examples of the foreign law.

DOI: 10.7256/2454-0706.2015.9.16171

Abstract: This article examines various legal aspects of the parental responsibility to provide for their underage children. A research is conducted on the historical development of this institution, including determination of the circle of the responsible parties, level of their responsibility and size of the alimony, as well as the conditions under which the responsibility to support an underage child is placed upon a parent. The author notes the similarities and differences on this issue within the countries of Anglo-Saxon and Muslim laws, as well as the Romano-Germanic legal system. The research is conducted on the example of Russian, Algerian, Moroccan, German, and Californian family law. The parental responsibility to support their underage children is an institution that is common to family law of all countries, and has emerged over the recent past. The main distinctions can be found between the countries of Muslim legal system on one hand, and the countries of Roman-Germanic and Anglo-Saxon legal systems on the other. These distinctions are expressed in the inequality of genders (mother and father) with regards to responsibility to provide for their underage children, but at the same time, these differences are rather relative.

DOI: 10.7256/2454-0706.2015.9.42640

Abstract: This article examines various legal aspects of the parental responsibility to provide for their underage children. A research is conducted on the historical development of this institution, including determination of the circle of the responsible parties, level of their responsibility and size of the alimony, as well as the conditions under which the responsibility to support an underage child is placed upon a parent. The author notes the similarities and differences on this issue within the countries of Anglo-Saxon and Muslim laws, as well as the Romano-Germanic legal system. The research is conducted on the example of Russian, Algerian, Moroccan, German, and Californian family law. The parental responsibility to support their underage children is an institution that is common to family law of all countries, and has emerged over the recent past. The main distinctions can be found between the countries of Muslim legal system on one hand, and the countries of Roman-Germanic and Anglo-Saxon legal systems on the other. These distinctions are expressed in the inequality of genders (mother and father) with regards to responsibility to provide for their underage children, but at the same time, these differences are rather relative.