THE LANDLORD’S LIEN IN COMPARATIVE PERSPECTIVE OF COMMON AND CIVIL (POLISH) LAW – SELECTED ISSUES

Abstrakt

The aim of this article is to conduct a fundamental analysis of the current selected issues regarding the landlord’s lien, in comparative perspective of common and civil (Polish) legal systems. This issue is lately under a constant development, since the lease agreement gin a substantial importance in the legal turnover both in Poland and common law countries, in particular United States of America. Therefore an approach to some of the most relevant legal problems of landlord’s lien, including specifically: types of landlords security interests, legal relation between statutory and contractual (consensual) lien, as well as the issues referring waiver and priority of the lien, seems to be beneficial in the light of resolving the present problems concerning landlord’s lien.