Possession was considered as a fact in Roman law with material and spiritual prerequisites, and as a right in Germaniclaw.
罗马法上占有为一种事实,其构成要件有物质要件和精神要件;
2
Based on Roman law and Germaniclaw and following the various other factors. States made the Civil Code of goodwill have different requirements.
基于对罗马法和日耳曼法的不同继受和其他因素的影响,各国民法典对善意取得有不同的规定。
3
Derived from the principle of "hand muss hand wahren" in Germaniclaw, bona fide gaining has been successfully incorporated into civil laws of all the countries.