The introduction of this thesis underlines the relevance of the subject of research by showing that the bankruptcy over property of a natural person, the consumer, is part of the legal tradition of the developed European and other countries, as well as the reality and necessity for the functioning of modern markets. The author highlights the fact that consumer bankruptcy is a part of bankruptcy law and that the analysis of this issue must take into account the characteristics of the bankruptcy system, factors that influence its formation, the necessary preconditions for its effective implementation and the economic situation in the country.The second part of the thesis deals with the historical development of the institute, ideas and interests in (consumer) bankruptcy. By outlining the developmental genesis focus is placed on the frail and often unstable interaction of legal rules in consumer bankruptcies and individual interests of creditors, the legality of the market and the general (public) interest. This historical development is considered to be the main reason why the bankruptcy proceedings over the assets of individuals were introduced relatively late, i.e. 30 years ago. The institute of consumer bankruptcy in the European legal systems was originally introduced in Denmark on May 9th, 1984 (Gældssaneringslov) and entered into force on July 1st, 1984, by adding section IV to the Bankruptcy Act (Konkurslov). The last country in the European legal order that introduced the consumer bankruptcy was Greece (Law no. 3816/10, Issued on 27 July 2010), whereas, for instance, it has not yet been implemented in the Italian legal system.Parts III and IV are central parts of this doctoral thesis. They discuss and present the comprehensive and systematic consumer bankruptcy regulations of the legal systems of the United States, England, Germany, France and Slovenia. This section discusses a number of issues, such as whether consumer bankruptcy should promote discipline, or should it be more tolerant and thus encouraging the entrepreneurial spirit? Should the impact of the law have wider social effects or is its purpose purely a rational resolution of a particular case? Should the effects that it has on employment be taken into account? Should out-of-court (informal) settlements be preferred over formal court proceedings? What is the role of the state? It is pointed out that, although there are many disputed issues, there are even more unresolved factors that affect possible answers. This results in numerous viewpoints and often a hampered ability to create and formulate a unified model of consumer bankruptcy. Analyzing the various modalities of consumer bankruptcy the author concludes that there is no Pareto optimum, i.e. a solution that would be ideal and acceptable to all participants in the consumer debts-discharge proceedings. Considering the similarities and differences of the illustrated models, the author offers an answer to the question of potential reception of the institute of consumer bankruptcy in the Republic of Croatia. In order to take a wider view of this issue and taking into account all the above stated factors, the thesis also deals with the social, economic and consumer objectives of debt consolidation process. It is pointed out that the adoption of the Bankruptcy Act 1997 (OG no. 44/96) represented a radical change in the way in which bankruptcy procedure was conducted in the Republic of Croatia. However, in this section the author refers to the essential reform introduced by the Bankruptcy Act 1997, or the introduction of bankruptcy over the property of individuals in view of the fact that the legislator decided that conditions for the introduction of a special kind of bankruptcy proceedings for all individuals are not ready yet, and that the bankruptcy proceedings can only be carried out over the property of an individual, i.e. traders and individual traders (Article 3 (1), Bankruptcy Act).Before concluding remarks the author provides guidance based on the European Convention for the Protection of Human Rights and Fundamental Freedoms (OG - IT, no. 18/97, 6/99, 14/02, 13/03, 9/05, 1/06 i 2/10) and the practice of the European Court of Human Rights, particularly on Article 1 Protocol No. 1 (Protection of property), Article 5 (Right to liberty and security), Article 6 (Right to a fair trial), Article 8 (Right to respect for private and family life) and Article 14 (Prohibition of discrimination).In conclusion, the focus is shifted to the dynamic nature of consumer bankruptcy within the analyzed jurisdictions of a long market tradition, noting that the new solutions will follow global trends, such as inflation, falling demand, rising costs, falling lending and a range of other factors rendering many consumers unable to repay their debt. The conclusion of the analysis is that in the context of constant change it is evident that the American concept of a fresh start, primarily bankruptcy under Chapter 7 of the Bankruptcy Code ( 700. to 785. 11 USC), undoubtedly affects the development of the European institute of automatic discharge of debts of consumers. From the Croatian perspective, opting for the need to introduce the institute of consumer bankruptcy, the intention is to show de lege ferenda solution and to argue that the need for any reform or implementation of consumer insolvency proceedings should be a legal framework for the release of the debts of insolvent individuals through a variety of options tailored to all types of borrowers - regardless of their financial situation.