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Notary in real terms in the world is basically the same, a special proof of activities carried out by specialized the judicial certification authority and a full-time legal staff, and its purpose is to prevent disputes and reduce litigation. The notary system first originated in the Roman civil legal system, after 2,000 years of development, has become an important legal system of the modern state of law. World's notary system is divided into two categories: civil law the state notarial system and common law countries notary system, the former represented by France, Germany, Japan, the latter represented by the United States, the United Kingdom. Notary system of civil law countries generally in real notary, the legal notary system is relatively sound, the notarial certificate legally binding, usually believe in notaries parochialism. Notary system of common law countries generally confined to the formal review, based on voluntary notary the notarial certificate does not have legal evidence of force and enforcement class, notaries can concurrently. This paper describes the notary system in Germany, France, Japan, the United States, the United Kingdom and other countries, a comparative analysis of these countries notary system from a notary public nature, a notary public, notary services, notary and legal responsibility. Our statute law countries, speaking from the legal and cultural traditions, the notary system of China's notary system and civil law countries closer. Therefore, in establishing sound of the notary system should be targeted at mainly to learn the system of civil law countries notary, to draw on the common law countries notary system supplemented. In March 2003, the International Union of Latin notary China 公证员协会 added external force to promote China's notary system closer to the civil law countries notary system. In this paper, the actual legislation of the Notary Law, based on our notary career development status, focus draws on the provisions of the civil law countries such as Germany, France, Japan, on the nature of the notaries and notary agencies, the provisions on statutory notary system, as well as electronic notarial business requirements, from the nature of the notaries and notary agencies innovation, the notarial business innovation, and strive to further enrich and improve China's notary system in theory. In order to solve the problem of the nature of the property of the institutions of a notary public and notarized, this article draws on a common practice in civil law countries, the nature of our notaries located in the main civil service attributes, supplemented by freelance property will be the most suitable for our country organizational forms taken by a notary public position in the partnership. In order to expand the business scope of China's notary fully learn the legal notary system of civil law countries, from the theoretically reconstructed the a legal notary system suitable for China's national conditions; addition, the article also details the electronic notary business requirements of the United States, from the legislative, technical field of exploration of the necessity and feasibility of building e-commerce notary system.
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