French System Builders and English Problem Solvers: Missed and Emerging Opportunities for Convergence of French and English Law*

From: Texas International Law Journal | Date: July 1, 2005| Author: Markesinis, Basil | Copyright information

I. COMMONLY BELIEVED CAUSES OF THE DIFFERENCES

Many in England take it for granted not only that French and English law are different from each other but also that in most respects the French and German legal structures and reasoning are closer to each other than either is to the English.1 At the political level, the French/German elective affinity is exemplified-at least in the minds of ordinary citizens-by the imaginative post-War close political links forged between the two countrie...

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