The Law Merchant, a precursor to trendy commercial law, emphasised the liberty to contract and alienability of property. As nationalism grew in the 18th and nineteenth centuries, the Law Merchant was incorporated into countries’ local law beneath new civil codes. In contrast to English frequent law, which consists of huge tomes of case law, codes in small books are simple to export and straightforward for judges to apply. However, at present there are signs that civil and customary law are converging.
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