The Set-off in French and German Legal Systems with an Approach to"Ghahri" Set-off in Iranian Law

The fall of the two opposing religions automatically to the extent that they equate with each other, from the moment of the intersection inspired by the term ipso jure in Roman law and influenced by the ideas of Duma and Putie in French law became a rule, but from there The concept of purity was largely exaggerated and unrealistic. In order to resolve the conflicts around it and bring it into line with reality, the concept of legal purity was enshrined in French civil law and the concept of declared purity in German law. Is. Article 295 of the Civil Code of Iran introduced the phrase "coercive purity" inspired by some views in Islamic jurisprudence and the written legal system. Due to the ambiguity in the meaning of the word "coercion" in jurisprudential books, most legal writers considered it as equivalent to automatic purity or legal purity. The purpose of this study is to examine the purity in the French and German legal systems by looking at the coercive purity in Iranian law and identifying the strengths, weaknesses and gaps of existing regulations and the research method in writing this article is analytical-descriptive. Finally, it seems that careful attention to the jurisprudential background of the subject and the expressions used in civil law brings coercive purity in civil law closer to the concept of declarative purity in German law and voluntary purity in Islamic jurisprudence.