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18 Comparison of Jurisdictions of the World

From: Governing Law Risks in International Business Transactions

Philip R. Wood

From: Oxford Legal Research Library (http://olrl.ouplaw.com). (c) Oxford University Press, 2023. All Rights Reserved.date: 02 June 2023


This chapter identifies the families of jurisdictions into eight families, explains how they were formed, and sets out the members of each group, the historical background of the family, and the legal culture and key indicators. It identifies a number of other jurisdictions that might serve as the governing law of international transactions. The main families of jurisdictions are the American common law jurisdictions, the English common law jurisdictions, the Napoleonic jurisdictions, the Roman-Germanic jurisdictions, the mixed civil/common law jurisdictions, Islamic jurisdictions, new or transition jurisdictions, and a small number of unallocated jurisdictions. A table sets out statistics about these jurisdictions, showing the predominant influence of England, France, and Germany, with a number of other influential countries historically, including the United States and the Netherlands.

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