ABSTRACT
The starting-point of any comparative study of French colonization must be to note the peculiar position in which France stood from the commencement. Colonization therefore, while a matter of economic life and death to England, was to France only an outlet for her energies. The civil code of French Africa largely retains the ideas of the Code Civil; that of the British lands is based on native customs, save those that are anti-social or employ methods that could not possibly be sanctioned under a civilized administration. The Code is made to fit the local conditions and is such that the natives can understand it. But even local native-courts are a comparatively recent innovation in French West Africa. The varying colonial policies of the Powers were becoming evident, and France, breaking both from her military methods and from the undue praise bestowed on one foreign system, adopted an elastic comparative view-point.
