A micro-comparative study is undertaken in this module to compare the matrimonial property regimes and connecting factors for determining the law applicable to the proprietary consequences of marriage of various legal systems. The intended outcome of this comparison is to provide suggestions for reform of these fields under South African law. Question: Conduct a comparative analysis on these two fields of law under two Anglo-American and two European Continental systems in order to make proposals for reform of these fields of law in South Africa. Your discussion has to include concrete proposals for reform based on the comparative analysis and also has to engage with the writings of scholars on this topic