ABSTRACT
Comparative law should begin at home. A failure to recognise the varieties of, say, abortion law within the Western Islands of Western Europe leads to a failure to capitalise on an opportunity for illustrating die many different processes by which democracies resolve human rights dilemmas. The most determined anti-British politicians in the Republic of Ireland can be heard calling for Irish law to emulate British law. The absence of the full prohibitions in England is especially disturbing. Many secular English commentators, from sociologists to media pundits, have analysed many post-War problems of English society in terms of racial disharmony. The European Court of Human Rights made short shrift of the arguments about the different home legal systems reflecting different moral values in the Dudgeon case when it required the UK government to bring Northern Ireland’s law into line with the rest of the UK by decriminalising homosexual practice.
