A comparative study of the prying office with the intention of benevolence in the law of Iran, Britain and the United States

The prying of other people's property is an operation that a person, with good faith and benevolent motive, performs to manage another's property. The provisions of prying transactions in Iran have always been ineffective, while in the transactions of Britain and the United States, it is sometimes partially invalid and sometimes correct. In Iranian law, the legal basis for the interference and possession of a prying manager in the property of others without the permission of the owner or deputy of the law, according to the rules of domination and respect for the property of individuals can be the jurisprudential rules of Can refer to the owner. But in British and American law, the administration of other people's property is justified by the rule of emergency representation. This means that if the emergency agent is successful in British and American law, the agent can return to the original for the costs of rescuing and preserving the original property. A comparative study of these operations will help to make these types of transactions more in line with public order and the globalization of contract law.