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Legal System

Civil Law

Also Known As Continental Law
Civil Law Family

Civil law is a legal system in which comprehensive written codes, rather than judicial precedent, are the primary source of law, with courts interpreting and applying the code rather than making binding law of their own. The tradition traces its intellectual roots to ancient Roman law, especially its sixth century compilation under the Byzantine Emperor Justinian I, the Corpus Juris Civilis, rediscovered and studied intensively in medieval European universities from the eleventh century onward, and took its modern codified form in the national civil codes enacted across Europe from the early nineteenth century, most influentially the Napoleonic Code of 1804. It is the most widespread legal system in the world today by number of jurisdictions, covering most of continental Europe, Latin America, and large parts of Africa and Asia.

Facts
Disputed
Origin Year
1804 2
1804, the enactment of the Napoleonic Code, is taken here as the origin of the modern codified civil law tradition, since it was the model most widely adopted or adapted by other nations. The tradition intellectual roots are far older, tracing to Roman law and particularly to Justinian own sixth century Corpus Juris Civilis, so which date counts as origin depends on whether the Roman legal inheritance or its modern codified form is meant.
Example Jurisdictions
France, Germany, Italy, Spain, most of continental Europe, Latin America, and large parts of Africa and Asia. 2
Primary Source of Law
Comprehensive written codes and statutes, with case law playing a secondary, interpretive role. 3
Classification
Legal Family
Civil Law 1
Civil Law
Filter Results4 entries
Connections

Includes

Source Abuse of Law (Max Planck Encyclopedia of European Private Law)
Accursius, Jurists

Traced as a distinct field to French droit administratif and the specialized administrative courts built around the Conseil d'Etat (1799); common law systems developed their own administrative law later, chiefly through the ordinary courts' power of judicial review rather than a separate administrative court system.

Source The Oxford Handbook of Comparative LawMathias Reimann and Reinhard Zimmermann, editors

Brazil's legal system sits within the civil law tradition; no live entity yet exists for the Supremo Tribunal Federal specifically.

Andres Bello, Jurists
Source Encyclopaedia Britannica
Atilicinus, Jurists
Basilika, Codes
Bulgarus, Jurists
Source An Introduction to Comparative LawKonrad Zweigert and Hein Koetz; English translation by Tony Weir
Source An Introduction to Comparative LawKonrad Zweigert and Hein Koetz; English translation by Tony Weir
Burgundian Code, Codes

Colombia's legal system sits within the civil law tradition; no live entity yet exists for the Constitutional Court of Colombia specifically.

Source Civil Code of the Empire of Ethiopia, 1960 (WIPO Lex)
Code of Euric, Codes
Source Major Legal Systems in the World TodayRene David and John E.C. Brierley
Corte d'Assise, Courts
Source Encyclopaedia Britannica

European Union regulation, applied across member states whose domestic systems are predominantly civil law.

Source Major Legal Systems in the World TodayRene David and John E.C. Brierley
Due Process, Doctrines

Civil law systems recognize analogous fair-procedure guarantees under related principles such as the rule of law and the principle of legality, rather than due process as such.

Ecloga, Codes

European Union directive, applied across member states whose domestic systems are predominantly civil law.

Source Major Legal Systems in the World TodayRene David and John E.C. Brierley

European Union regulation, applied across member states whose domestic systems are predominantly civil law.

Source Major Legal Systems in the World TodayRene David and John E.C. Brierley

European Union regulation, applied across member states whose domestic systems are predominantly civil law.

Source Major Legal Systems in the World TodayRene David and John E.C. Brierley
Source Law of France (Wikipedia)
Gaius Aculeo, Jurists

Applies EU-wide, and most EU member states are civil law jurisdictions; the United Kingdom, an EU member state when the GDPR took effect, retained a near-identical UK GDPR after leaving the EU despite being a common law jurisdiction.

Source Major Legal Systems in the World TodayRene David and John E.C. Brierley
Source General State Laws for the Prussian States (Wikipedia)

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Hugo Grotius, Jurists

His formal legal training and Dutch offices sit within the Roman-Dutch civil law tradition; his best-known contribution founded international law as a field distinct from any one domestic legal system this atlas currently mints (no international-law legal-system entity exists here; named in prose rather than forced onto an edge, matching this atlas's own established convention for a claim with no clean live target).

Source Encyclopaedia Britannica
Hypothec, Doctrines
Source Hypothec (Wikipedia)
Irnerius, Jurists

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Source An Introduction to Comparative LawKonrad Zweigert and Hein Koetz; English translation by Tony Weir

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Legal good, Doctrines
Source Legal good (Wikipedia)
Lex Alamannorum, Codes
Lex Frisionum, Codes
Lex Ripuaria, Codes

European Union directive, applied across member states whose domestic systems are predominantly civil law.

Source Major Legal Systems in the World TodayRene David and John E.C. Brierley
Source Matrimonial regime (Wikipedia)
Napoleonic Code, Codes
Source Major Legal Systems in the World TodayRene David and John E.C. Brierley

Family classification carried over from this entity's own recorded SubLabel (Civil Law Family), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Obrogation, Doctrines
Source Obrogation (Wikipedia)
Odofredus, Jurists
Source Patrimony of affectation (Wikipedia)

European Union directive, applied across member states whose domestic systems are predominantly civil law.

Source Major Legal Systems in the World TodayRene David and John E.C. Brierley

Comparative law generally classifies contemporary Chinese law as a socialist legal system within the broader civil-law family, developed by legislative codification rather than common-law judicial precedent.

Source Personal Information Protection Law of the People's Republic of China (Wikipedia)
Placentinus, Jurists
Precedent (Stare Decisis), Doctrines

Civil law courts follow jurisprudence constante, a settled line of decisions expected to be followed in the ordinary course, but are not doctrinally bound to a single prior decision the way stare decisis binds a common law court.

Source Stare Decisis (Legal Information Institute, Cornell Law School)

Named here for its documented Roman law and French Revolutionary lineage, the doctrine own historical origin point. It is equally recognized in common law systems, where it is treated as a foundational right of criminal procedure.

Source Major Legal Systems in the World TodayRene David and John E.C. Brierley

Originated in German civil law administrative and constitutional doctrine and remains most fully developed there and across the EU's civil law member states; increasingly adopted in common law judicial review as well, notably in the United Kingdom.

Source The Oxford Handbook of Comparative LawMathias Reimann and Reinhard Zimmermann, editors
Source REACH, Regulation (EC) No 1907/2006 (EUR-Lex)
Rechtsstaat, Doctrines
Source Rechtsstaat (Wikipedia)

European Union directive, applied across member states whose domestic systems are predominantly civil law.

Source Major Legal Systems in the World TodayRene David and John E.C. Brierley

Montesquieu wrote within the French civil law tradition; many civil law constitutions adopt an explicit tripartite structure influenced by his formulation.

Source Montesquieu (Wikipedia)
Source Servitude in civil law (Wikipedia)
Sextus Pedius, Jurists

European Union directive, applied across member states whose domestic systems are predominantly civil law.

Source Major Legal Systems in the World TodayRene David and John E.C. Brierley
Source An Introduction to Comparative LawKonrad Zweigert and Hein Koetz; English translation by Tony Weir
Source Synallagmatic contract (Wikipedia)
Source An Introduction to Comparative LawKonrad Zweigert and Hein Koetz; English translation by Tony Weir
Source An Introduction to Comparative LawKonrad Zweigert and Hein Koetz; English translation by Tony Weir
Titus Accius, Jurists
Source An Introduction to Comparative LawKonrad Zweigert and Hein Koetz; English translation by Tony Weir
Usufruct, Doctrines
Source Usufruct (Wikipedia)
Vacarius, Jurists
Visigothic Code, Codes

European Union directive, applied across member states whose domestic systems are predominantly civil law.

Source Major Legal Systems in the World TodayRene David and John E.C. Brierley

Held Differently

Why this is disputed. The CJEU is a supranational court whose case law draws heavily on continental civil law method and whose member states are mostly civil law jurisdictions, but EU law itself is often described by comparative scholars as a distinct legal order rather than a member of any single one of the five traditions; the civil law classification here reflects the Court's dominant working method, not a claim that EU law is simply continental civil law.

Source The Oxford Handbook of Comparative LawMathias Reimann and Reinhard Zimmermann, editors
Habeas Corpus, Doctrines

Civil law systems generally provide analogous judicial protection against arbitrary detention through differently named procedures rather than through habeas corpus as such.

Source Habeas Corpus (Legal Information Institute, Cornell Law School)
Judicial Review, Doctrines

Civil law jurisdictions generally exercise constitutional review through a single dedicated constitutional court rather than diffusing it across the ordinary judiciary as the United States does, a different account of the same underlying power rather than a rejection of it.

Mens Rea, Doctrines

Civil law systems reach a broadly comparable result through the distinct concepts of dol (intent) and culpa (fault) rather than through mens rea as such, a different account of criminal culpability rather than a rejection of it.

Source Mens Rea (Wikipedia)
M'Naghten Rules, Doctrines

Civil law systems generally excuse a mentally disordered defendant through their own non-responsibility provisions (for example Article 122-1 of the French Penal Code), a differently framed doctrine reaching a broadly similar result rather than the M'Naghten test itself.

Source M'Naghten Rules (Wikipedia)
Rule of Law, Doctrines

Civil law systems generally express the rule of law through the Rechtsstaat tradition and codified principles of legality rather than through the common law rule of law as such.

Legal Family Of

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)
Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)
Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)
Source List of national legal systems (Wikipedia)
Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)
Source List of national legal systems (Wikipedia)
Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)
Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)
Source List of national legal systems (Wikipedia)
Source List of national legal systems (Wikipedia)
Source List of national legal systems (Wikipedia)
Source List of national legal systems (Wikipedia)
Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)
Source List of national legal systems (Wikipedia)
Source List of national legal systems (Wikipedia)
Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)
Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)
Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Open Questions

Source An Introduction to Comparative LawKonrad Zweigert and Hein Koetz; English translation by Tony Weir
In the Other Atlases
Sources
1. Wikipedia: Civil law
Civil law (legal system), or continental law, a legal system originating in continental Europe and based on Roman lawView the Source
2. Major Legal Systems in the World Today
Rene David and John E.C. Brierley, Stevens and Sons, 1985
3. An Introduction to Comparative Law
Konrad Zweigert and Hein Koetz; English translation by Tony Weir, Clarendon Press, Oxford, 1998
The Oxford Handbook of Comparative Law
Mathias Reimann and Reinhard Zimmermann, editors, Oxford University Press, 2006
  • Includes: Court of Justice of the European Union (CJEU)
  • Includes: Administrative Law
  • Includes: Proportionality
Encyclopaedia Britannica
Encyclopaedia Britannica, Inc.
  • Includes: Hugo Grotius
  • Includes: Andres Bello
  • Includes: Dalmacio Velez Sarsfield
View the Source
Personal Information Protection Law of the People's Republic of China (Wikipedia)
Includes: Personal Information Protection Law (PIPL)View the Source
Abuse of Law (Max Planck Encyclopedia of European Private Law)
Includes: Abuse of RightsView the Source
Rechtsstaat (Wikipedia)
Includes: RechtsstaatView the Source
REACH, Regulation (EC) No 1907/2006 (EUR-Lex)
Publications Office of the European UnionIncludes: REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals)View the Source
Montesquieu (Wikipedia)
WikipediaIncludes: Separation of Powers, Lead paragraph - in-legal-system civil-law
Quote, Includes: Separation of Powers, Lead paragraph - in-legal-system civil-law
a French jurist, historian, and political philosopher
View the Source
Law of France (Wikipedia)
WikipediaIncludes: French Legal SystemView the Source
M'Naghten Rules (Wikipedia)
Includes: M'Naghten RulesView the Source
Stare Decisis (Legal Information Institute, Cornell Law School)
Includes: Precedent (Stare Decisis)
Mens Rea (Wikipedia)
WikipediaIncludes: Mens ReaView the Source
Habeas Corpus (Legal Information Institute, Cornell Law School)
Includes: Habeas CorpusView the Source
Civil Code of the Empire of Ethiopia, 1960 (WIPO Lex)
Includes: Civil Code of Ethiopia (1960)
List of national legal systems (Wikipedia)
  • Legal Family Of: Legal System of Cuba, Section: Civil law
    Cuba
  • Legal Family Of: Legal System of Vietnam, Section: Civil law
    Vietnam
  • Legal Family Of: Law of Spain, Section: Civil law
    Spain
  • Legal Family Of: Law of Ethiopia, Section: Civil law
    Ethiopia
  • Legal Family Of: Law of Greece, Section: Civil law
    Greece
  • Legal Family Of: Law of Colombia, Section: Civil law
    Colombia
  • Legal Family Of: Law of Iceland, Section: Civil law
    Iceland
  • Legal Family Of: Law of Austria, Section: Civil law
    Austria
  • Legal Family Of: Law of Estonia, Section: Civil law
    Estonia
  • Legal Family Of: Law of Bolivia, Section: Civil law
    Bolivia
  • Legal Family Of: Law of Ecuador, Section: Civil law
    Ecuador
  • Legal Family Of: Law of Paraguay, Section: Civil law
    Paraguay
  • Legal Family Of: Law of Lebanon, Section: Civil law
    Lebanon
  • Legal Family Of: Law of Mongolia, Section: Civil law
    Mongolia
  • Legal Family Of: Law of Slovenia, Section: Civil law
    Slovenia
  • Legal Family Of: Law of Andorra, Section: Civil law
    Andorra
  • Legal Family Of: Law of Timor-Leste, Section: Civil law
    Timor-Leste
  • Legal Family Of: Law of Armenia, Section: Civil law
    Armenia
  • Legal Family Of: Law of the Dominican Republic, Section: Civil law
    Dominican Republic
  • Legal Family Of: Law of Angola, Section: Civil law
    Angola
  • Legal Family Of: Law of Belarus, Section: Civil law
    Belarus
  • Legal Family Of: Law of Benin, Section: Civil law
    Benin
  • Legal Family Of: Law of Bosnia and Herzegovina, Section: Civil law
    Bosnia and Herzegovina
  • Legal Family Of: Law of Burkina Faso, Section: Civil law
    Burkina Faso
  • Legal Family Of: Law of Cabo Verde, Section: Civil law
    Cape Verde
  • Legal Family Of: Law of the Central African Republic, Section: Civil law
    Central African Republic
  • Legal Family Of: Law of Chad, Section: Civil law
    Chad
  • Legal Family Of: Law of the Republic of the Congo, Section: Civil law
    Republic of the Congo
  • Legal Family Of: Law of Costa Rica, Section: Civil law
    Costa Rica
  • Legal Family Of: Law of Cote d'Ivoire, Section: Civil law
    Ivory Coast
  • Legal Family Of: Law of Gabon, Section: Civil law
    Gabon
  • Legal Family Of: Law of Georgia (country), Section: Civil law
    Georgia
  • Legal Family Of: Law of Guatemala, Section: Civil law
    Guatemala
  • Legal Family Of: Law of Guinea-Bissau, Section: Civil law
    Guinea-Bissau
  • Legal Family Of: Law of Haiti, Section: Civil law
    Haiti
  • Legal Family Of: Law of Vietnam, Section: Civil law
    Vietnam
  • Legal Family Of: Law of North Macedonia, Section: Civil law
    North Macedonia
  • Legal Family Of: Law of Mozambique, Section: Civil law
    Mozambique
  • Legal Family Of: Law of Uzbekistan, Section: Civil law
    Uzbekistan
  • Legal Family Of: Law of Montenegro, Section: Civil law
    Montenegro
  • Legal Family Of: Law of Syria, National legal systems table, Syria
    Based on Napoleonic civil law.
View the Source
General State Laws for the Prussian States (Wikipedia)
Includes: General State Laws for the Prussian States, Wikipedia lead sentence
Quote, Includes: General State Laws for the Prussian States, Wikipedia lead sentence
The code had over 17,000 articles, and covered fields of civil law, penal law, family law, public law, administrative law etc.
View the Source
Usufruct (Wikipedia)
Includes: Usufruct, Wikipedia lead sentence
Quote, Includes: Usufruct, Wikipedia lead sentence
fructus) is a limited real right (or in rem right) found in civil law and mixed jurisdictions that unites the two property interests of usus and fr
View the Source
Hypothec (Wikipedia)
Includes: Hypothec, Wikipedia lead sentence
Quote, Includes: Hypothec, Wikipedia lead sentence
hypothēkē), sometimes tacit hypothec, is a term used in civil law systems (e.g. the law of most of Continental Europe) to refer to a registered
View the Source
Synallagmatic contract (Wikipedia)
Includes: Synallagmatic contract, Wikipedia lead sentence
Quote, Includes: Synallagmatic contract, Wikipedia lead sentence
In civil law systems, a synallagmatic contract is a contract in which each party to the contract is bound to provide something to the other party
View the Source
Legal good (Wikipedia)
Includes: Legal good, Wikipedia lead sentence
Quote, Includes: Legal good, Wikipedia lead sentence
In the civil law tradition, a legal good is an interest or right that the legal system protects
View the Source
Obrogation (Wikipedia)
Includes: Obrogation, Wikipedia lead sentence
Quote, Includes: Obrogation, Wikipedia lead sentence
In civil law, obrogation (Latin: obrogat from obrogare) is the modification or repeal of a law in whole or in part by issuing a new law
View the Source
Patrimony of affectation (Wikipedia)
Includes: Patrimony of affectation, Wikipedia lead sentence
Quote, Includes: Patrimony of affectation, Wikipedia lead sentence
In certain civil law jurisdictions (e.g., France, Quebec, Mexico, etc.), the patrimoine d'affectation is property, assets, or a legal estate that can
View the Source
Servitude in civil law (Wikipedia)
Includes: Servitude in civil law, Introduction
Quote, Includes: Servitude in civil law, Introduction
At civil law, ownership (dominium) (e.g.
View the Source
Matrimonial regime (Wikipedia)
Includes: Matrimonial regime, Introduction
Quote, Includes: Matrimonial regime, Introduction
Matrimonial regimes are applied either by operation of law or by way of prenuptial agreement in civil-law countries, and depend on the lex domicilii of the spouses at the time of or immediately following the wedding.
View the Source
Open Questions (1 open question)
Is Socialist Law a Distinct Legal Family, or a Variant of the Civil Law Tradition?

Comparativists have never fully settled this. Rene David's influential classification treated socialist law (the historical Soviet system and its export to Eastern Europe, China and elsewhere) as a family of its own, defined by the subordination of law to Communist Party policy and state ownership, even though its courts, codes and legal vocabulary were built on a civil-law base. Zweigert and Kotz, working from a different comparative method, are more skeptical that this political fact by itself creates a distinct legal FAMILY rather than a civil-law variant under unusual political conditions, and post-1989 practice complicates the question further: China's law today keeps socialist characteristics in name while its commercial and procedural codes converge heavily with mainstream civil law.

What would resolve this A comparative-law consensus classification would need to specify which feature is doing the definitional work, legal FORM (codes, courts, procedure, which stayed civil-law in shape) or POLITICAL FUNCTION (subordination to party policy, which did not), since the two point to different answers; a jurisdiction-by-jurisdiction study tracking how far post-1989 codes have converged with ordinary civil law would also narrow the question for any single country.
Konrad Zweigert and Hein Koetz; English translation by Tony Weir, An Introduction to Comparative Law
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