Marked by long histories, proud of their own distinctive traditions, and mindful of their idiosyncrasies, France and the United Kingdom would seem, at first sight, to have totally different legal systems.
French law, born of Roman law, is written, codified and ruled by principles. English law is pragmatic, often unwritten and based on precedent. Other differences between French and English law concern the organisation of the legal system, the role of judges and, particularly, the significance of the State.
But are the differences really so great? The authors underline how the two traditions have travelled along different paths to ultimately converge, in the present era of European integration.
This book provides a highly accessible comparative study of the two great legal traditions that grew out of Roman law, on one hand, and from common law, on the other. The information summarised here is essential for anyone wishing to understand current discussions about the development of public law and justice.

Bernard Stirn is a member of the French Council of State, adjunct president of the litigation section. He is a professor at the Institut d’Etudes Politiques of Paris and at the Ecole Nationale de l’Administration.
Duncan Fairgrieve and Mattias Guyomar teach public law at the University of Paris-I.