Sunday, 8 November 2015

Are there English-speaking countries that have a Civil Code? And are there non-English-speaking countries without a Civil Code?

Working on my taxonomy paper – one of the reviewers doesn’t like the variable on ‘English as one of the official languages’. Now, I’ll use whether countries have a ‘Civil Code’ (including countries with a Code of Obligations but not simply a contract act) as a proxy – based on the thinking that those two variables are fairly well correlated. But there are some differences, based on data for 156 countries:

Civil Code

So, which type of countries are behind the two exceptions?
  • The eight countries with a Civil Code but English language are some of the mixed legal systems, ie English is one of the official languages but there is distinct (sometimes even dominant) civil law influence, eg, Eritrea, Mauritius, Malta, Philippines.
  • The 18 countries without a Civil Code but also without English language are the Nordic countries, a minority of countries from the former Yugoslavia and the Middle East, some mixed legal systems (Israel, Sri Lanka), and some countries which are typically classified as common law one but which don’t have English as an official language any more (eg, Bangladesh, Cyprus, Nepal).