On: French Appeal Court affirms decision that copyrigh...

[leoc]

> the U.K.'s [...] common law

You mean England-and-Wales' and Northern Ireland's common law ofc! :)

[Blikkentrekker → leoc]

This is interesting new information to me, but I looked it up and Scotland indeed has what many consider a mixed system, quite unique since the U.K. is a unitary state.

I was already aware that Scotland uniquely for the U.K. has the unus testis, nullus testis principle which is ubiquitous in civil law systems, but I had no idea of how far reaching it was.

https://en.wikipedia.org/wiki/Common_law#Scotland

Regardless, looking at this map of the world here:

https://commons.wikimedia.org/wiki/File:Map_of_the_Legal_sys...

It is quite clear that continental Europe shares more with even China than it does with say, England, Australia, or the U.S.A..

[kazen44 → Blikkentrekker]

civil law is obviously based on the "code civil" from the french republic and to a lesser extent ancient roman civil law.

The fact that most of the world has this system is quite easily explained. mainly thanks to colonialism and imperialism.

China adopted a similair system after the boxer rebellion.

[Blikkentrekker → kazen44]

I think many civilizations independently invented it.

The innovation that law is written down by lawmakers is not that hard to duplicate. If anything, the opposite happened and high frequency of common law in the world is purely because the British Empire was the largest empire to have ever existed and all states that utilize common law descend from the British Empire.

Until the British Empire, common law existed only on the British Isles and the rest of the world had civil law.