Annual Survey of International & Comparative Law


Renunciation and remission are not comprehensively treated in recent Israeli legislation. And although the legislature has referred to these terms in the course of its legislation, they are nowhere defined.

Therefore, in order to examine the terms under discussion, we shall follow a comparative approach.' In so doing, we shall also look to Jewish law. We will focus on the question of whether we are concerned with 1) a unilateral or bilateral act and 2) upon the issue of what approach would be most suitable for future legislation. We shall conduct our study in the light of the historical development of Israeli law by examining the Mejelle, Jewish law, English law, as well as other legal systems.