The scope and content of property rights in any given jurisdiction reflects fundamental issues underpinning that society’s socio-economic and cultural foundations. Pertinently, the level of protection accorded to property rights determines the scope and content of such rights, and also the inevitable interest of society in private property. These positions illustrate that a property rights system is contested space, pitting the interests of the private owner against the interest of the society at large.

This research makes an analysis of the extent that he property regimes of Zimbabwe, South Africa and Germany reflect this contestation between private interest and social responsibility. It questions whether societal objectives are integral to the right of ownership in the three jurisdiction. IT, however, concedes that there are no single approach countries have sought to follow in striking a balanced property rights framework. Through a comparative analysis, it concludes that he inevitability of societal objectives in the right ownership must be accepted but that such a position, must undermine the worth and value in the content of the right of ownership.