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Scotland and South Africa are two of the leading jurisdictions which integrate English common law with Continental civil law. This volume examines their experience and considers the sider lessons both for mixed legal systems and for the development of a European private law.

Civil law --- Obligations (Law) --- Property --- Civil law. --- Comparative law. --- Civil law - Scotland. --- Civil law - South Africa. --- Obligations (Law) - Scotland. --- Obligations (Law) - South Africa. --- Property - Scotland. --- Property - South Africa.