This is an explanation for the difference in the land regisration in civil and common law countries.
Every real property is registered in some form or other by the state or an institution designated by the state. One of the most important purpose of such registration is to collect taxes, as well as to facilitate property transaction by providing a clear system for identifying individual property items.
This registration, however, is based on different methods in various legal systems. Basically, we can differentiate between two systems, one that is based on the registration of the document, and the other based on the registration of the title of ownership to the real property.
Document registration is widely used in common law jurisdictions. In this case the documents related to the property are registered. Such documents are generally called deeds. Various types of deeds are prepared for every transaction or other event related to the real property, such as transfer, donation, establishing any encumbrance, etc. Since every single action is based on a deed, it also called the deeds registration system.
Title registration is the name of the system administered by the Land Registration Office in civil law countries. The title to each piece of land is registered in the land register, and the title is then guaranteed by the state and the information contained therein is non-appealable until and unless the opposite is proven.
