선박저당권에 관한 비교법적 고찰

A Comparative research on the Ship Mortgage

The biggest problem with ship mortgage system is that there are no laws about ship mortgage system. All laws related to ship mortgage are based largely on real estate mortgage in Civil Law. But it is not properly prepared. The peculiarity of marine enterprises is not considerd. So to operate the ship mortgage system more effectively, the special law-making or such legal complements as the simplification of procedure are needed. This paper deals with ship mortgage system and is centered on what is the subject of ship mortgage, how it should be set up, what are the priorities and the range and extinctive reason of ship mortgage. And it compares the 1993 convention and the ship morttgage system of major shipping countries with ours and suggests the ways to activate our ship mortgage system.