ABSTRACT
Legal systems are customarily grouped into various blocs:1 the civil law, deriving principally from Justinian’s Corpus Juris Civilis (and its more recent avatars, the Code Napoleon and the German Bürgerliches Gesetzbuch) considered extant throughout the EU, Latin America, the Caribbean, Turkey, Japan,2 Korea, various portions of Africa, the Philippines and other areas of the Pacific, and notably in Louisiana, Puerto Rico and Scotland (in modified form); the common law, deriving from English judicial tradition and currently considered extant throughout the Commonwealth, India,3 Ireland and the United States; socialist and post-socialist law,4 the former still to be found in communist Asia, Cuba and several African nations, and the latter in the defunct socialist and communist States of eastern and western Europe;
1 FH Lawson, A Common Lawyer Looks At The Civil Law (University of Michigan, 1955) 3. 2 Japan adopted a civil law tradition along the lines of the German codes, but, after World War II, fell
under the influence of the American common law, particularly in its public law. Japan is thus a ‘mixed system’. JH Merryman, The Civil Law Tradition: An Introduction to the Legal Systems of Western Europe and Latin America (Stanford University Press, 1985) 5.
