Accurate conceptual interface is a prerequisite for mutual understanding and reference be-tween different legal cultures and provides new perspectives for observing Chinese domestic law as well.This article attempts to find corresponding terms in German law for some selected Chinese legal concepts relating to multiple debtors,so as to explore the causes of the problem with the conceptual interface and its practical constellations,as well as the potential function of the conceptual interface.In the field of substantive law,by examining the conceptual interface between the Chinese and German terms of non-genuine joint and several liability,supplementary liability and degree of causation,we can better explain to overseas scholars the logic behind the diversification of liability forms and the mainstreaming of several liability with regards to multiple tortfeasors under Chinese law.By analyzing the connectivity between the seemingly identical concepts of the right of contribution and the right of statutory subrogation in Chi-nese and German law,this article reveals their fundamental differences and illustrates the root and effects of the differences in the paths of solving the problem of statute of limitations of joint and several liability between the two jurisdictions.In the field of procedural law,taking the interface between Chi-nese and German law on the types of joinder of parties as an entry point,it can be found that Chinese law has ambiguous consciousness of the joinder of parties being a plurality of claims(actio),which leads to a lack of clear understanding of the relationship between the parties and then to a completely dif-ferent perception of the subject matter of the dispute and res judicata from that of the German ones.It re-sults in a huge divergence in the approaches to solving relevant problems and difficulties in conducting dialogs.Improving the awareness of the interface between legal concepts and paying attention to the evo-lution of foreign concepts in the Chinese domestic context will help Chinese scholars to communicate ef-fectively in exchanges with foreign scholars and explore the uniqueness of Chinese law.
joint and several liabilitydegree of causationindependent tortfeasorsjoinder of partiesthird-party notice
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