ABSTRACT
Comparative law - the comparison of the different legal systems of the world (Zweigert and Katz, 1987:2) - offers the example of a scholarly enterprise that has developed explicit conceptual frameworks for comparison between state legal systems. The idea of 'legal families', for example, whatever its difficulties, suggests that different state legal systems, or central elements of legal doctrine within them (including styles of developing and presenting doctrine, and of legal reasoning and interpretation), can be treated as having sufficient similarity to make comparison fruitful. At the same time, it suggests that these comparable systems or system elements treated as a group can be distinguished from others treated, for certain analytical purposes, as qualitatively more remote (see, for example, Zweigert and Katz, 1987:ch.5; David and Brierley, 1985:17-22).
