ABSTRACT
Unlike contract law, where China had significant policy and legal antecedents to guide legal reform, property law reform had little in the way of precedent.2 Property rights in traditional China provided some guidance, but in the main Chinese legal specialists working on property rights were compelled to look abroad for guidance. The adoption of foreign law norms, however, is moderated by local tradition and norms of political and legal culture. In particular, the individualist orientation of liberal property rights regimes conflicts with the collectivist norms in China, while private rights discourses of liberalism conflict with the public law norms of Chinese tradition and PRC policy. The development of property rights in the PRC is largely a process of mediating these conflicts.
