Submission of sales of goods in the Exchange Guarantee or risk transfer in Imami and Iranian law and the Convention on the International Sale of Goods through a Comparative Study of the law of England

Surrendering the deal and paying the transaction price is the target conclusion of any contracts. Sales contract and its consequences have been the issue of concentration in the legal texts and the law of I. R. of Iran. These have been 33 legal rules directly and indirectly devoted to these issues and the legislator has directly allocated 18 articles of the Civil Codes to the surrendering provisions. United Nations Convention on Contracts for the International Sale of Goods (CISG – 1980) consists of four chapters and 101 articles There are several solutions in connection with the Exchange Guarantee or risk transfer in domestic law: the date of conclusion of the contract (Article 185 Swiss liability law)، the date of transfer of ownership (Article 1138 French Civil Code)، time delivery of the object of sale (Article 387 Iranian Civil Code)، and filed autonomy (of England).. In this study through following relatively the same logic، the researcher has categorized the topics and dealt with comparative aspects while explaining the differences and shared concepts of the CISG، jurisprudence، civil law of Iran and England. In spite of their slight differences، efforts are made to offer a way to create convergence between the legal systems of the above، and international conventions such as CISG. Documentation and analysis captured Article 367 to 399 of Iranian Law and CISG articles 30 to 46 and 60 to 70 which comparatively studied with the Britain’s Sale of Goods Act 1979. This study is descriptive and analytic in nature. Methodology employed is essentially based on theoretical، descriptive، analytical and comparative research approaches done in the library via note taking.