A Class Action in Various Legal Systems

Abstract

The article is devoted to the application of the class action institution in different countries and legal systems. The article deals with questions about the meaning of the institute of class action, interests protected with the help of it, positive and negative aspects of this institution are estimated. In addition, the article analyses characteristics and conditions of presentation of the class action. The research was conducted by using general scientific and specific methods of research including the analogy method, formal logical and comparative law methods. As a result, the Russian institute of class action, by its characteristics, is classified as a continental model. The analysis of the latest changes in Russian legislation reveals, at the same time, a tendency to converge with the Anglo-Saxon model of private class action.