Comparative study on the legal systems of the protection of adults lacking legal capacity: National rules of private law, of private international law and a possible legislative initiative of the European Union (United Kingdom, France, Germany, Sweden, Czech Republic, Romania)

This study provides an in-depth and objective comparative analysis of the legal systems of protection of adults lacking legal capacity within selected EU Member States. The first two parts of the study contain, for each Member State concerned, a detailed description and assessment of the national provisions of private law and of international private law on the protection of adults lacking legal capacity. The final part of the study indicates and evaluates the advantages and the possible content of a legislative initiative of the EU in the field of the protection in crossborder situations of adults lacking legal capacity.