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Transplants, Legal Borrowing and Reception as

The terms legal transplant, legal borrowing, and reception are commonly used to address the same phenomenon, namely the spread and dissemination of legal models from a donor or exporting legal order to a receiving one. More broadly, reception, transplant, and borrowing refer to the result of a legal reform process that is initiated by a project of legal change based on imitation of laws, doctrines, or judicial decisions already in place in different legal orders.

Within the fabric of such terminology, the notion of legal transplant has been, for the last three decades, the most central. This is largely due to the successful and widely discussed 1974 book by the legal historian Alan Watson, which he devoted to a specific set of borrowings within the realm ...

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