Legal extension of the term of the lease : a comparative study of Jordanian and English law.
This thesis is based on the legal comparison of Jordanian and English law. The main
focus of the study carried out is legal extension of the term of the lease. The study aims to
prove that it is currently possible for Jordanian law to be enriched by English law, and
that borrowing from English law, could bridge certain gaps in the Jordanian Landlord and
Tenant Act of 1994, with regard to legal extension.
In addition, the study aims to make Jordanian as well as English law more accessible to
the reader. That is to provide the reader with a clear picture about the English legal
system and English property law, which is not well-known in the Middle East, and about
the Jordanian legal system and Jordanian property law, which is not known in Europe.
In addition to the comparison as a fundamental research method, interviews are
employed. Also, both qualitative and quantitative research data are generated. Interviews
are conducted with 9 landlords, 9 tenants and 12 jurists covering the three biggest cities in
Jordan: Amman, Irbid and Zarqa.
The thesis is comprised of eleven chapters. Chapters one and two provide an introduction
to the study and outline to the Jordanian legal system. Chapters three and four discuss
borrowing from English to Jordanian law and the methodology of the research. Chapters
five and six deal with the concept of property, and contract and the concept of tenancy in
Jordanian and English law. Chapters seven and eight set out the background to the
problem of housing and business in Jordan and the legislator'S role, and discuss the
court's role in the process of extension and repossession. Chapters nine and ten focus on
legal extension of the term of the lease in English law and discuss the implications of
legal extension of the term of the lease on the different aspects of life in Jordan (the
findings of the interviews). Chapter eleven presents the research findings and
In each chapter of the thesis, the relevant rules under the law, or the laws concerned are
discussed. and then followed by a comparison, or a conclusion, that may be drawn from