The Returning of Possession Will in Iranian Civil Law, A Comparative Study in Egyptian and English Law1

Apart from that “Possession Will” which known as unilateral or bilateral contract it accepted as returnable or revocable by testator in the statutes of the most state. But the views are different that the testator has right forfeited his returning of possession will from himself or not. In Iranian Civil Law and Imamiyeh Jurisprudence if this clause included from within will certainly unreliable. If this right forfeited concluded with from within bilateral contract some lawyers know it null because it is contrary to spiritual law and some of them knows it correct. in Egyptian Law this clause is null. In English Law because returning of possession will is counted as essential elements of will, it is order not merely right and to take consideration forfeited this right is impossible. This research to describe this right and present a comparative study with Egyptian and English Law for this respect that to earn common basis and choice view that has most conformity with parallel to statute and Imamiyeh Jurisprudence.