ABSTRACT
Legal systems are not randomly distributed around the world.1 Most jurisdictions inherit their legal system from an invader, an occupier or a colonial power. 2 Few countries have actually chosen their legal system as the outcome of a conscious debate over the existing possibilities.3 The standard examples are Japan, Thailand and the Ottoman Empire, countries that by the end of the nineteenth century favoured civil law (German in the fi rst case and French in the last two cases) over available alternatives at the time. 4 The reasons for their choice had less to do with economic effi ciency and more to do with the perception of the fast growing French and later German power (military more than economic) and modernization.5
