The Codification of Civil Law in Quebec: An Example for Vietnam?

Abstract

The Quebec legal system is one of the few hybrid legal systems of the world that combines both common law and civil law. While the civil law regime in Quebec is mainly inspired by the Napoleon Code, the Civil Code of France, it still remains being influenced by the common law system, for example for its extensive reliance on jurisprudence. As it is the case for Quebec, the French Civil Code has also been heavily influential on the codification of the Vietnam’s Civil Code. Vietnam’s use of legal transplants also shows the impact of other legal systems on its own. In this paper, the author aims to brush an overview of the Quebec civil law codification that includes some comparisons with the Vietnam civil law regime.