Comparative analysis of the concept of bankruptcy in Iranian law, French and British law

There are two significant issues in a bankruptcy event, first the people who go bankrupt and then the stop component. Now, who is bankrupt and the concept of stopping is different in different countries. In the law of the Anglo-Saxon countries and the new law of France, there is no difference between a businessman and a non-businessman, and all persons are subject to bankruptcy. In Iranian law, only businessmen and commercial companies are subject to bankruptcy. But the concept of debt relief does not exist in any of these systems. However, determining the appropriate concept of the concept of stopping is very important. In this article, we are in a position to use descriptive and analytical methods to determine the policies of various legislators in explaining the concept of suspension and to reach a balanced view of it in a way that adds to the dynamism of the bankruptcy process. Bankruptcy has social consequences, including unemployment for workers.