Rechtgeshafteljunstic acts),which was created by Heise &Hugo,has no counterpart in Anglo-American legal system .It is praised highly in civil law system. J.H. Merryman once said it was the proudest achievement in civil law system .The German Civil Code (BOB ) first made it as an institution in law in 1896. The Japanese Civil Law Code,Civil Code of Republic of China,Korea Civil Code also followed this legislation practice. But some famous jurists such as Zweigert and Koetz argued that it was not a...