Civil law, common law distinctions and implications for lawyers in international transition



As the world becomes more and more connected, many lawyers have chosen to leave their home countries to become certified lawyers and practice law in other jurisdictions. In addition to the procedural requirements that lawyers must comply with in order to obtain a license in different countries and jurisdictions, lawyers interested in this transition must also familiarize themselves with the legal system of the new country. First, it is essential that lawyers understand the difference between the two dominant systems of law, civil law and common law, as these systems represent different ways of obtaining justice. Additionally, understanding the distinctions between the two systems and their implications is imperative not only for lawyers who intend to practice across borders, but also for law firms looking to operate and operate. represent clients internationally.

It is important to note that civil law and common law are the two main legal systems in the world. Currently, around 150 countries and the province of Quebec, Canada, adopt the civil law system, including China, Brazil, Germany, and France, while around 80 countries have chosen common law, including United States, England and Canada, excluding Quebec. . The most notable difference between the two systems is that the common law is mainly based on judicial precedents, where previous judicial decisions are of paramount importance, while in civil law, codified laws prevail. In practice, however, many countries adopt a mixture of the characteristics of the two systems.

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