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The ruling on trades that the seller does not own is one of the most important cases of conflict between Iranian law and the law of the British and France and Germany.In this article situation of conflict of interest buyer in good faith and the owner has been studied and the main approach is to explain the role of good faith in property ownership. In the light of the comparative analysis of the constructive role of good faith in the transactions and the approach of different legal systems, the basic criteria for selecting the appropriate rule appear.how to identify a good base of support from the buyer in good faith in the legal system relying on the foundations of legal systems is different. on the one hand, the common feature of the rights of England, France and Germany is the promise of the transfer of ownership by some examples of goodwill transactions on the other hand, differences in the laws and doctrines in the legal environment of the countries as well as in the judicial process make the subject matter complex in the comparative debate. After analyzing the main source of Good faith-based rules for Europe, from the point of view of economic rights (in other words, analyzes that are consistent with commercial necessities), the essential factors in identifying the desired, the rules of the transactions are dealt with and the necessity of adopting such views is explicitly stated.

Keywords: Bona Fide Acquirer, Property Acquisition, Original owner, Apparent Agency, Market overt Rule

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