ABSTRACT

There seems to be no consensus on what is meant by mixed legal systems or mixed jurisdictions (Palmer 2008). The classic approach is to limit mixed jurisdictions to private law systems based on a mixture of common law and civil law (Palmer 2008: 7). The modern, broader approach is to take a legal pluralistic approach that regards mixed jurisdictions as involving two or more different legal systems or traditions within a country’s legal system (Palmer 2008: 13). Given the trend toward the globalization of legal practice and legal education, particularly clinical legal education (see generally Bloch 2011: xxv), I intend to adopt the broader pluralistic approach for the purposes of this chapter.