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.

This book provides a history of some of the main institutions of South African private law and in so doing explores the process through which integration of the English common law and the continental civil law came about in that jurisdiction. Here is a book aimed at both European and South African audiences. For European lawyers it provides a stimulating insight into the way the process of harmonization of private law has occurred in South Africa and may occur within the European Union. By analysing the historical evolution of the most important institutions of the law of obligations and the...