The Master's thesis analyses the similarities, differences and peculiarities of personal bankruptcy in the Slovenian and Croatian legal system, as well as the available statistical data on personal bankruptcy proceedings in the context of a comparative legal perspective obtained from the Slovenian and Croatian Ministries of Justice. The introduction presents a comparative legal analysis of the basic regulatory models of personal bankruptcy for consumers, entrepreneurs and private individuals, and discusses the purpose of the basic rules. The central part of the Master's thesis is devoted to the key issues of the differences and suitability of personal bankruptcy in the two jurisdictions with a critical review of the controversies and dilemmas that arise in practice. Particular attention is paid to the criteria and conditions and key innovations for the discharge of the debtor's brought by the amendment H of the Zakon o finančnem poslovanju, postopkih zaradi insolventnosti in prisilnem prenehanju, the ZFPPIPP (Law on financial transactions, insolvency proceedings and compulsory liquidation), and the amendment to the Croatian Bankruptcy Law, the duration of the trial period, the assets of the debtor entering the bankruptcy estate, and a comparative legal analysis of Slovenian and Croatian solutions in practice. The ordinary consumer bankruptcy, the out-of-court procedure and the simple consumer bankruptcy procedure, which is dealt in a separate law in Croatia, are analysed in detail. The Slovenian legal system in the ZFPPIPP regulates the Consumer bankruptcy, but does not regulate the specific out-of-court and simple consumer bankruptcy proceedings, which is a specialty of the Croatian legal order. In the conclusion, the author provides a general assessment of the effects of the new Slovenian and Croatian legislation in the field of personal bankruptcy, as well as identifies challenges that require appropriate legal solutions.
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