船舶物权变动登记效力的理论解析——兼论我国《物权法》关于物权变动登记效力立法模式的选择

物权变动登记的效力存在对抗要件主义和生效要件主义之别。在分析两种立法例的基础上，本文指出了我国物权变动应采取与船舶物权变动相同的立法模式，即应采取对抗要件主义立法，并对我国《物权法》提出了修改意见。

On the Effect of Registry of Alteration of Real Rights in Ships --The Choice of Legislation Mode of the Real Rights Act Concerning the Effect of Registry of Alteration of Real Rights

There are two different isms in the effect of alteration registry of real rights in ships,which one of them provides the real rights in ships shall act against a third party after registered,whereas the other one provides the real rights in ships shall not go into effect unless they are registered.On the basis of analysis of the two isms,this paper proposes that the alteration of real rights in ships shall adopt the legislation mode that registry shall not act against a third party unless registered.And the Real Rights Act shall adopt the same legislation mode as the alteration of real rights in ships does.This paper also puts foreword suggestions on the amendments of the Real Rights Act of the P.R.C.