This article considers the process of historical development of the bankruptcy and insolvency laws in the United Kingdom, the United States and Australia. The central point is to demonstrate that the process has been one ofprogressive liberalisation of consequences accompanied either by increased regulation or new and innovate flexible techniques of creditor involvement. We conclude the article with an examination ofthe operation ofthe deed ofcompany arrangement, or DOCA, in Australia and a recent liberalisation involving a practitioner-led
32 pagesBANKRUPTCY EdelmanJ14Jan2019
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