James Edelman, Henry Meehan, Gary Cheung
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 of progressive liberalisation of consequences accompanied either by increased regulation or new and innovative flexible techniques of creditor involvement. We conclude the article with an examination of the operation of the deed of company arrangement, or DOCA, in Australia and a recent liberalisation involving a practitioner-led
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