comparative study of tort liability of the exploiter of aircraft

the owner of the aircraft or the enterprise which benefits from its use or operation may have civil liability for injuries to persons or property on the land or water or in the sky. regarding this liability many questions can be raised: who is the responsible person and what are the harmful acts and damages which can be resulted from using aircraft and how can harmonize the property rights of persons on the land or water with the right of flying aircrafts? what is the foundation of liability: fault or strict liability? using comparative study, we have answered to these questions and in addition to description of the present situation of legal systems, some proposals have been offered to remove the defects and fill the gaps of iran's legal system.