Differences Between English and French Law

The differences between France and England are not only geographical and cultural but also legal.

The roots of French Law 

In common with many countries on the continent the French legal system is rooted in Roman law and belongs to the civil law tradition, as opposed to the Common law system found in England, America and most Commonwealth countries. This often leads to significant differences in substantive and procedural law, not to mention professional practice, which at times may surprise not to say confuse those attuned to the Common law environment.

Furthermore, the past few decades have been marked in France by a trend towards ever more extensive legislation and regulations on matters as varied as planning, environmental and consumer protection, not to mention tax law, which require ever more attention from people proposing to buy property or opening a business in that jurisdiction.

Two areas of noticeable difference between English law and French law are to be found in the fields of property law and property litigation.