Abstraction principle (law)
The abstract system dominates the entire BGB and is vital for the understanding of how it treats legal transactions, such as contracts.Although abstract title transfer seemingly contradicts the usual common sense interpretation of commercial transactions, it is undisputed among the German legal community.Critics say that what German legal scholars call Verpflichtungsgeschäft and Verfügungsgeschäft (i.e. undertakings vs. conveyance) are actually the same thing, but expressed in other words.This is the main criticism of those jurisdictions that follow the opposite system, the causal system of title transfer (Germ: Kausalprinzip or Prinzip der kausalen Tradition), which follows the canon law maxim solo consensus obligat, under which the meeting of the minds in a contract of sale is sufficient both to create obligations and convey title.This includes mainly jurisdictions that have adopted or been influenced by the Napoleonic Code, e.g. France, Louisiana, Quebec, Portugal, French-speaking Africa, much of Latin America, etc.