@article{MAKHILLTSS20138622474,
    title = {Comparative Analysis of Discharge of Contractual Obligations in Iran and Malaysia},
    journal = {The Social Sciences},
    volume = {8},
    number = {6},
    pages = {618-627},
    year = {2013},
    issn = {1818-5800},
    doi = {sscience.2013.618.627},
    url = {https://makhillpublications.co/view-article.php?issn=1818-5800&doi=sscience.2013.618.627},
    author = {Sakina Shaik Ahmad,Mehdi,Suzanna Mohamed and},
    keywords = {Contract,obligation,discharge,civil code,common law,Iran,Malaysia},
    abstract = {The discharge of obligation is one of the most important legal 
  issues to which special attention has been paid in both Iranian and Malaysian 
  laws. Under Article 264 of the Iranian Civil Code, an obligation is discharged 
  in one of the following ways: Fulfillment of the obligation, cancellation of 
  agreement by mutual consent, release from obligation, substitution of a different 
  obligation, set off and recoupment and acquisition of debt. In effect, Iranian 
  legislation provides six modes of discharge of obligation. In Malaysian law 
  on the other hand, an obligation is discharged through one of the following 
  4 ways: Performance, frustration, agreement and breach. With regard to form 
  the Iranian Civil Code is dependent on a written legal system (the Roman-Germanic 
  legal system) but in terms of content, it is influenced by Islamic law. By contrast, 
  the Malaysian legal system is considerably influenced by an unwritten legal 
  system (the common law). The task of this study is to examine and critique the 
  modes of discharge of obligation under Iranian law in comparison with those 
  under Malaysian law. The central goal is to remove the ambiguities and related 
  problems observed in the Iranian law in order to give it greater efficacy. The 
  research is a library-based type with a comparative analytic method.}
    }