Common law,



However, codification is by no means a defining characteristic of a civil law system, as e. g.the civil law systems of Scandinavian countries remain largely uncodified, whereas common law jurisdictions have frequently codified parts of their laws, e. g. in the U. S. Uniform Commercial Code. There are also mixed systems, such as the laws of Scotland, Louisiana, Quebec, Namibia and South Africa. Thus, the difference between civil law and common law lies less in the mere fact of codification, but in the methodological approach to codes and statutes. In civil law countries, legislation is seen as the primary source of law.




By contrast, court opinions in German-speaking countries can be as long as English ones, and normally discuss prior cases and academic writing extensively. There are, however, certain sociological differences. Civil law judges are usually trained and promoted separately from advocates, whereas common law judges are usually selected from accomplished and reputable advocates. Also, the influence of articles by legal academics on case law tends to be much greater in civil law countries.