Mixed Legal Systems

Mixed legal systems, or jurisdictions, as they are classically called, make up roughly fifteen political entities, of which eleven are independent countries. Most (excluding Scotland and Israel) of these are the former colonial possessions of France, Netherlands, or Spain, which were subsequently transferred to Great Britain or the United States.

Their inelegant name is an accident of history. Legal cartographers during the height of the British empire were unable to fit these entities into the civil law or common law mold, which dominated their thinking, and hence simply called them mixed or hybrid to indicate their otherness. Though comparative law classification schemes have long since been improved and expanded, the group continues to be referred to by this name, in part because of tradition and convenience ...