Seven legal systems, twenty everyday arguments

Every cell below is a question, and every one of these systems has an answer to it. What differs is where the answer is kept. The filled cells hold a provision of the code and link to its official text; the rest name what answers it instead — an Act this collection does not carry, or the courts.

Legal systems
7
Everyday arguments
20
Answered by a provision
101
Not answered, with a reason
39

Who has a provision for what

Rows are problems, columns are legal systems. A cell with a citation in it links to the page reproducing that provision's official text. A cell without one names what answers the problem instead; select it to read the full note.

  • The courts answer it No statute governs the point, and none is needed: the rule is judge-made. Negligence, private nuisance, Rylands v Fletcher, abatement, a common-law debt, deceit, caveat emptor — all of these are law, and none of them is in a code to quote.
  • In law we don't carry The rule exists and is written down, in a statute outside the corpus behind these pages: special legislation, another code, or municipal law. This one is our limit, not the system's.
  • No page written yet The provision is in the corpus these pages are built from and nobody has written it up. This is the one kind that is our gap rather than a finding, and it is listed so it can be closed.
Twenty compared problems against seven legal systems. Each row links to the full comparison; each citation links to the provision.
The argument answered in this code Italia Codice Civile 17/20 France Code civil 16/20 Deutschland BGB 19/20 España Código Civil 19/20 United Kingdom UK legislation 9/20 California California law 11/20 New York New York law 10/20
The landlord will not repair: damp, mould and no heating in 7 jurisdictions 7 in a code, 9 recorded differences Art. 1575 Italia: Art. 1575 Codice Civile Art. 1578 Italia: Art. 1578 Codice Civile Art. 1719 France: Art. 1719 Code civil § 535 Deutschland: § 535 BGB § 536 Deutschland: § 536 BGB Art. 1554 España: Artículo 1554 del Código Civil LTA 1985 s. 11 United Kingdom: LTA 1985 s. 11 CIV § 1941 California: CIV § 1941 CIV § 1942 California: CIV § 1942 N.Y. Real Property Law § 235-b New York: N.Y. Real Property Law § 235-b
Locked out: the landlord changed the locks and cut the power, in 7 jurisdictions 6 in a code, 10 recorded differences Art. 1168 Italia: Art. 1168 Codice Civile Art. 1170 Italia: Art. 1170 Codice Civile Code pénal, art. 226-4-2 France: In law we don't carry — Code pénal, art. 226-4-2. Read why. § 858 Deutschland: § 858 BGB § 861 Deutschland: § 861 BGB Art. 446 España: Artículo 446 del Código Civil HA 1988 s. 27 United Kingdom: HA 1988 s. 27 HA 1988 s. 28 United Kingdom: HA 1988 s. 28 CIV § 1940.2 California: CIV § 1940.2 N.Y. Real Property Law § 235 New York: N.Y. Real Property Law § 235
Noise from the neighbours: what the law says in seven countries 6 in a code, 13 recorded differences Art. 844 Italia: Art. 844 Codice Civile Art. 1253 France: Art. 1253 Code civil § 906 Deutschland: § 906 BGB Art. 1908 España: Artículo 1908 del Código Civil EPA 1990 s. 79 United Kingdom: EPA 1990 s. 79 EPA 1990 s. 80 United Kingdom: EPA 1990 s. 80 United Kingdom: 1 more provision, on the comparison CIV § 3479 California: CIV § 3479 Private nuisance; NYC Noise Code New York: The courts answer it — Private nuisance; NYC Noise Code. Read why.
Separated parents who cannot agree where the children live: what the law says in six jurisdictions 6 in a code, 12 recorded differences Art. 337-ter Italia: Art. 337-ter Codice Civile Art. 373-2-9 France: Art. 373-2-9 Code civil Art. 373-2 France: Art. 373-2 Code civil § 1671 Deutschland: § 1671 BGB § 1684 Deutschland: § 1684 BGB Art. 92 España: Artículo 92 del Código Civil Art. 94 España: Artículo 94 del Código Civil CA 1989 s. 8 United Kingdom: CA 1989 s. 8 CA 1989 s. 1 United Kingdom: CA 1989 s. 1 FAM § 3011 California: FAM § 3011 FAM § 3040 California: FAM § 3040 DRL § 240 New York: No page written yet — DRL § 240. Read why.
Someone's child damaged my property: what the law says in six jurisdictions 6 in a code, 12 recorded differences Art. 2048 Italia: Art. 2048 Codice Civile Art. 1242 France: Art. 1242 Code civil § 832 Deutschland: § 832 BGB Art. 1903 España: Artículo 1903 del Código Civil The parent's own negligence United Kingdom: The courts answer it — The parent's own negligence. Read why. CIV § 1714.1 California: CIV § 1714.1 N.Y. General Obligations Law § 3-112 New York: N.Y. General Obligations Law § 3-112
The seller knew about the defect and said nothing: what the law says in 7 jurisdictions 6 in a code, 13 recorded differences Art. 1490 Italia: Art. 1490 Codice Civile Art. 1495 Italia: Art. 1495 Codice Civile Art. 1641 France: Art. 1641 Code civil Art. 1644 France: Art. 1644 Code civil § 434 Deutschland: § 434 BGB § 444 Deutschland: § 444 BGB Art. 1484 España: Artículo 1484 del Código Civil Art. 1486 España: Artículo 1486 del Código Civil Caveat emptor; Misrep. Act 1967 United Kingdom: The courts answer it — Caveat emptor; Misrep. Act 1967. Read why. CIV § 1710 California: CIV § 1710 CIV § 1572 California: CIV § 1572 N.Y. Real Property Law § 462 New York: N.Y. Real Property Law § 462 N.Y. Real Property Law § 465 New York: N.Y. Real Property Law § 465
The tenant has stopped paying and will not leave: what the law says in six jurisdictions 6 in a code, 11 recorded differences Art. 1591 Italia: Art. 1591 Codice Civile Loi n° 89-462 du 6 juillet 1989 France: In law we don't carry — Loi n° 89-462 du 6 juillet 1989. Read why. § 543 Deutschland: § 543 BGB § 546 Deutschland: § 546 BGB Art. 1569 España: Artículo 1569 del Código Civil HA 1988 s. 7 United Kingdom: HA 1988 s. 7 HA 1988 s. 8 United Kingdom: HA 1988 s. 8 CIV § 1946.2 California: CIV § 1946.2 N.Y. Real Property Law § 216 New York: N.Y. Real Property Law § 216
Who stays in the family home: separation and the house in six legal systems 6 in a code, 11 recorded differences Art. 337-sexies Italia: Art. 337-sexies Codice Civile Art. 215 France: Art. 215 Code civil § 1361b Deutschland: § 1361b BGB § 1568a Deutschland: § 1568a BGB Art. 96 España: Artículo 96 del Código Civil MCA 1973 s. 24 United Kingdom: MCA 1973 s. 24 MCA 1973 s. 25 United Kingdom: MCA 1973 s. 25 Family Code § 6321 California: In law we don't carry — Family Code § 6321. Read why. N.Y. Domestic Relations Law § 234 New York: N.Y. Domestic Relations Law § 234
A dog bit someone: what the law says in five countries 5 in a code, 7 recorded differences Art. 2052 Italia: Art. 2052 Codice Civile Art. 1243 France: Art. 1243 Code civil § 833 Deutschland: § 833 BGB Art. 1905 España: Artículo 1905 del Código Civil Animals Act 1971 United Kingdom: In law we don't carry — Animals Act 1971. Read why. CIV § 3342 California: CIV § 3342 Agriculture and Markets Law New York: In law we don't carry — Agriculture and Markets Law. Read why.
I lent a friend money with nothing in writing: what the law says in five jurisdictions 5 in a code, 10 recorded differences Cod. civ. artt. 1813-1820 Italia: No page written yet — Cod. civ. artt. 1813-1820. Read why. Art. 1902 France: Art. 1902 Code civil § 488 Deutschland: § 488 BGB Art. 1753 España: Artículo 1753 del Código Civil A common-law debt United Kingdom: The courts answer it — A common-law debt. Read why. CIV § 1622 California: CIV § 1622 CIV § 1624 California: CIV § 1624 N.Y. General Obligations Law § 5-701 New York: N.Y. General Obligations Law § 5-701
Siblings inherited the house and one will not sell: what the law says in 7 jurisdictions 5 in a code, 9 recorded differences Art. 713 Italia: Art. 713 Codice Civile Art. 1111 Italia: Art. 1111 Codice Civile Art. 815 France: Art. 815 Code civil § 2032 Deutschland: § 2032 BGB Art. 1051 España: Artículo 1051 del Código Civil Art. 400 España: Artículo 400 del Código Civil TOLATA 1996 s. 14 United Kingdom: TOLATA 1996 s. 14 TOLATA 1996 s. 15 United Kingdom: TOLATA 1996 s. 15 The Probate Code California: In law we don't carry — The Probate Code. Read why. EPTL; SCPA New York: In law we don't carry — EPTL; SCPA. Read why.
The landlord kept the deposit: how five legal systems decide who was right 5 in a code, 12 recorded differences L. 392/1978, art. 11 Italia: In law we don't carry — L. 392/1978, art. 11. Read why. Art. 1731 France: Art. 1731 Code civil § 551 Deutschland: § 551 BGB Art. 1561 España: Artículo 1561 del Código Civil Art. 1562 España: Artículo 1562 del Código Civil Housing Act 2004, ss. 212-215 United Kingdom: In law we don't carry — Housing Act 2004, ss. 212-215. Read why. CIV § 1950.5 California: CIV § 1950.5 N.Y. General Obligations Law § 7-103 New York: N.Y. General Obligations Law § 7-103 N.Y. General Obligations Law § 7-108 New York: N.Y. General Obligations Law § 7-108
Sold as seen: the second-hand car that broke down, in four civil codes and three common-law systems 4 in a code, 11 recorded differences Art. 1490 Italia: Art. 1490 Codice Civile Art. 1495 Italia: Art. 1495 Codice Civile Art. 1641 France: Art. 1641 Code civil Art. 1648 France: Art. 1648 Code civil § 434 Deutschland: § 434 BGB § 437 Deutschland: § 437 BGB Deutschland: 2 more provisions, on the comparison Art. 1484 España: Artículo 1484 del Código Civil Art. 1485 España: Artículo 1485 del Código Civil España: 2 more provisions, on the comparison United Kingdom: The courts answer it. Read why. Fraud, not warranty California: The courts answer it — Fraud, not warranty. Read why. Fraud, and the contract New York: The courts answer it — Fraud, and the contract. Read why.
The builder did the work badly and will not come back: what the law says in 7 jurisdictions 4 in a code, 9 recorded differences Art. 1667 Italia: Art. 1667 Codice Civile Art. 1669 Italia: Art. 1669 Codice Civile Art. 1792 France: Art. 1792 Code civil Art. 1792-6 France: Art. 1792-6 Code civil § 633 Deutschland: § 633 BGB § 634 Deutschland: § 634 BGB Deutschland: 1 more provision, on the comparison Art. 1591 España: Artículo 1591 del Código Civil Defective Premises Act 1972 United Kingdom: In law we don't carry — Defective Premises Act 1972. Read why. Civ. Code §§ 895-945.5 California: In law we don't carry — Civ. Code §§ 895-945.5. Read why. Breach of contract New York: The courts answer it — Breach of contract. Read why.
The landlord wants to raise the rent: four systems that limit it, and three civil codes that say nothing 4 in a code, 11 recorded differences L. 392/1978; L. 431/1998 Italia: In law we don't carry — L. 392/1978; L. 431/1998. Read why. Loi n° 89-462, art. 17-1 France: In law we don't carry — Loi n° 89-462, art. 17-1. Read why. § 558 Deutschland: § 558 BGB Ley de Arrendamientos Urbanos, art. 18 España: In law we don't carry — Ley de Arrendamientos Urbanos, art. 18. Read why. HA 1988 s. 13 United Kingdom: HA 1988 s. 13 HA 1988 s. 14 United Kingdom: HA 1988 s. 14 CIV § 1947.12 California: CIV § 1947.12 N.Y. Real Property Law § 226-c New York: N.Y. Real Property Law § 226-c
The neighbour's tree hangs over my garden: what the law says in four countries 4 in a code, 11 recorded differences Art. 896 Italia: Art. 896 Codice Civile Art. 892 Italia: Art. 892 Codice Civile Art. 673 France: Art. 673 Code civil Art. 671 France: Art. 671 Code civil § 910 Deutschland: § 910 BGB Art. 592 España: Artículo 592 del Código Civil Art. 591 España: Artículo 591 del Código Civil Abatement: common-law self-help United Kingdom: The courts answer it — Abatement: common-law self-help. Read why. Abatement, at common law California: The courts answer it — Abatement, at common law. Read why. New York: The courts answer it. Read why.
The other parent stopped paying: child maintenance in four civil codes 4 in a code, 11 recorded differences Art. 337-ter Italia: Art. 337-ter Codice Civile Art. 337-septies Italia: Art. 337-septies Codice Civile Art. 371-2 France: Art. 371-2 Code civil Art. 208 France: Art. 208 Code civil § 1601 Deutschland: § 1601 BGB § 1603 Deutschland: § 1603 BGB Deutschland: 1 more provision, on the comparison Art. 93 España: Artículo 93 del Código Civil Art. 142 España: Artículo 142 del Código Civil Child Support Act 1991 United Kingdom: In law we don't carry — Child Support Act 1991. Read why. Family Code § 4055 California: In law we don't carry — Family Code § 4055. Read why. DRL § 240(1-b) New York: In law we don't carry — DRL § 240(1-b). Read why.
Water coming through the ceiling from the flat above: what the law says in 7 jurisdictions 4 in a code, 6 recorded differences Art. 2051 Italia: Art. 2051 Codice Civile Art. 1242 France: Art. 1242 Code civil § 823 Deutschland: § 823 BGB Art. 1910 España: Artículo 1910 del Código Civil Negligence, nuisance, Rylands United Kingdom: The courts answer it — Negligence, nuisance, Rylands. Read why. Negligence California: The courts answer it — Negligence. Read why. Common-law negligence New York: The courts answer it — Common-law negligence. Read why.
Who owns the boundary wall and who pays to repair it: 4 civil codes, and 3 systems with no rule at all 4 in a code, 10 recorded differences Art. 880 Italia: Art. 880 Codice Civile Art. 653 France: Art. 653 Code civil Art. 655 France: Art. 655 Code civil § 921 Deutschland: § 921 BGB Art. 572 España: Artículo 572 del Código Civil Art. 575 España: Artículo 575 del Código Civil Party Wall etc. Act 1996 United Kingdom: In law we don't carry — Party Wall etc. Act 1996. Read why. The deed, or an easement California: The courts answer it — The deed, or an easement. Read why. The deed, or an easement New York: The courts answer it — The deed, or an easement. Read why.
Who pays for the roof and the lift: shared building costs in four legal systems 4 in a code, 9 recorded differences Art. 1118 Italia: Art. 1118 Codice Civile Art. 1123 Italia: Art. 1123 Codice Civile Italia: 1 more provision, on the comparison Loi du 10 juillet 1965 France: In law we don't carry — Loi du 10 juillet 1965. Read why. Wohnungseigentumsgesetz Deutschland: In law we don't carry — Wohnungseigentumsgesetz. Read why. Art. 395 España: Artículo 395 del Código Civil LTA 1985 s. 19 United Kingdom: LTA 1985 s. 19 LTA 1985 s. 20 United Kingdom: LTA 1985 s. 20 Davis-Stirling Act California: In law we don't carry — Davis-Stirling Act. Read why. N.Y. Real Property Law § 339-m New York: N.Y. Real Property Law § 339-m N.Y. Real Property Law § 339-x New York: N.Y. Real Property Law § 339-x

A column total counts provisions of one code, not answers. It is not a score and it is not a measure of how much law a place has. England and Wales fills nine of these twenty cells and answers all twenty — much of its answer is judge-made, and a common-law system with a thin column here is a system that writes less of its law into codes, which is a fact about legal form and nothing else.

See the seven placed by how often they agree →

Where the answer is, when it is not in the code

Forty of the hundred and forty cells hold no provision, and none of them means the system is silent on the problem. Each was reached by putting the same question to every corpus and recording what came back, and each note names what does answer it. They fall into three kinds.

In law we don't carry

21 of 39

The rule exists and is written down, in a statute outside the corpus behind these pages: special legislation, another code, or municipal law. This one is our limit, not the system's.

  • France Locked out: the landlord changed the locks and cut the power, in 7 jurisdictions

    Code pénal, art. 226-4-2

    France abolished the possessory actions — the reintegrande and the complainte — by loi n. 2015-177 of 16 February 2015, which repealed art. 2279 of the Code civil. The remedy moved wholesale to the juge des referes and to art. 226-4-2 of the Code penal, which makes it an offence to force an occupier out of his home without a court decision. So the Code civil genuinely has no article for this, and its absence here is a change in French law rather than a gap in the corpus.

  • France The tenant has stopped paying and will not leave: what the law says in six jurisdictions

    Loi n° 89-462 du 6 juillet 1989

    Recovering possession of a French dwelling is not Code civil business. It is loi n° 89-462 of 6 July 1989 and the code des procédures civiles d'exécution, neither of which is in the corpus behind these pages. The Code civil lease articles that survive — art. 1728 among them, which does have a page — state the tenant's duty to pay and to use the premises as agreed, but they no longer govern how a landlord gets a home back. This is the same shape of absence as French co-ownership, where the answer sits in the loi du 10 juillet 1965.

  • California Who stays in the family home: separation and the house in six legal systems

    Family Code § 6321

    A lookup miss rather than a gap in the law. California would answer this with Family Code § 2550, which requires equal division of the community estate and does have a page in this corpus, and with § 6321 on exclusive use of the dwelling, which does not. The lookup answered the custody half of the prompt instead and returned §§ 3040, 3044 and 3100, none of which is about the house. Rather than attach a member that does not answer the question asked, California is recorded as absent here; § 2550 answers who ends up owning what, which is a different question from who stays in the house while it is being decided.

  • United Kingdom A dog bit someone: what the law says in five countries

    Animals Act 1971

    Dog attacks in England and Wales are governed by the Animals Act 1971 and the Dangerous Dogs Act 1991. Neither is among the Acts this section carries — the UK corpus here holds the Children Act 1989, the Environmental Protection Act 1990, the Housing Act 1988, the Landlord and Tenant Act 1985, the Matrimonial Causes Act 1973, the Partnership Act 1890 and TOLATA 1996 — so there is no section to place beside the other five.

  • New York A dog bit someone: what the law says in five countries

    Agriculture and Markets Law

    New York's dog-bite rule lives in the Agriculture and Markets Law and in case law about an animal's vicious propensities. The New York corpus behind these pages covers the Domestic Relations Law, the General Obligations Law, the Partnership Law and the Real Property Law, none of which contains an animal-liability provision. The absence is a limit of the corpus, not a finding that New York has no rule.

  • California Siblings inherited the house and one will not sell: what the law says in 7 jurisdictions

    The Probate Code

    Administration of a deceased person's estate in California is governed by the Probate Code, which is not in this corpus, so there is no page to link. The lookup returned nothing with a page. California does have a partition procedure for co-owned real property, but it sits outside the Civil Code sections published here.

  • New York Siblings inherited the house and one will not sell: what the law says in 7 jurisdictions

    EPTL; SCPA

    The same: New York's succession law is the Estates, Powers and Trusts Law together with the Surrogate's Court Procedure Act, neither of which is in this corpus. The lookup produced RPL § 240-c, on severing a joint tenancy, which is a different mechanism — it operates between living co-owners and does not address the division of an estate among heirs.

  • Italia The landlord kept the deposit: how five legal systems decide who was right

    L. 392/1978, art. 11

    The Codice Civile contains no security-deposit provision. The three-month cap and the obligation to pay legal interest on an Italian residential deposit are art. 11 of L. 392/1978, a housing statute outside this corpus. A lookup returned arts. 1590 and 1587 on the condition of the property at handover, which answer the deduction question but not the deposit question, so Italy is recorded as absent rather than represented by a near-miss.

  • United Kingdom The landlord kept the deposit: how five legal systems decide who was right

    Housing Act 2004, ss. 212-215

    Deposit protection in England and Wales is Housing Act 2004 ss. 212-215 - the tenancy deposit schemes, the prescribed information and the penalty of one to three times the deposit - and that Act is not in the UK corpus. A lookup reached instead for Housing Act 1988 s. 21, which is about ending an assured shorthold tenancy and is the wrong end of the tenancy entirely.

  • United Kingdom The builder did the work badly and will not come back: what the law says in 7 jurisdictions

    Defective Premises Act 1972

    The Defective Premises Act 1972 and the Building Act 1984 are not in this corpus, and outside them a botched bathroom in England is an ordinary breach-of-contract claim developed by the courts rather than a code guarantee. The lookup returned nothing from the Acts the corpus does hold.

  • California The builder did the work badly and will not come back: what the law says in 7 jurisdictions

    Civ. Code §§ 895-945.5

    California does have a construction-defect statute — Civ. Code §§ 895 to 945.5, the SB 800 regime — but it has no pages in this section, so there is nothing here to link to. The lookup instead offered rescission under §§ 1689 and 1691 and the damages measure at § 3333, which are general contract law and not a builder's guarantee.

  • Italia The landlord wants to raise the rent: four systems that limit it, and three civil codes that say nothing

    L. 392/1978; L. 431/1998

    Residential rent and its indexation in Italy are L. 392/1978 and L. 431/1998, not the Codice Civile. The code governs the general obligations of landlord and tenant and stops there: the lookup answered with arts. 1575 and 1587, which set out what each party owes the other and say nothing about increases. Italy is absent from this comparison because the Italian answer was legislated out of the civil code decades ago.

  • France The landlord wants to raise the rent: four systems that limit it, and three civil codes that say nothing

    Loi n° 89-462, art. 17-1

    The same in France: revision of a residential rent is art. 17-1 of the loi n. 89-462 and the IRL index published by INSEE, both outside the Code civil. The lookup found only art. 1103, that lawfully formed contracts bind the parties - true, and useless to a tenant facing a large increase.

  • España The landlord wants to raise the rent: four systems that limit it, and three civil codes that say nothing

    Ley de Arrendamientos Urbanos, art. 18

    The same again in Spain: rent revision on a residential lease is art. 18 of the Ley de Arrendamientos Urbanos. The lookup returned arts. 1556 and 1569 of the Codigo Civil, which are about breach of the lease and grounds for eviction - a neighbouring subject, not this one.

  • United Kingdom The other parent stopped paying: child maintenance in four civil codes

    Child Support Act 1991

    Child maintenance in England and Wales is assessed administratively by the Child Maintenance Service under the Child Support Act 1991 formula, and the courts are largely ousted from setting the amount. Nothing in the UK corpus answers the question 'how much'. The lookup reached for Matrimonial Causes Act 1973 ss. 23 and 25, which are the financial provision and property powers between spouses, not the child maintenance calculation - so the absence here is a real feature of English law rather than a gap in the corpus.

  • California The other parent stopped paying: child maintenance in four civil codes

    Family Code § 4055

    California's guideline formula is Family Code § 4055, which has no page in this corpus. The lookup returned §§ 3010 and 3028, neither of which is a page and neither of which is about the amount of support. The contrast with the civil codes is the point: California legislates an algebraic formula where Italy, France, Spain and Germany legislate a proportionality standard.

  • New York The other parent stopped paying: child maintenance in four civil codes

    DRL § 240(1-b)

    New York's percentages are in Domestic Relations Law § 240(1-b), the Child Support Standards Act, which has no page here. The lookup found DRL § 244, which turns arrears into a money judgment, and § 248 - both enforcement provisions rather than provisions about the amount. New York therefore appears in this corpus on the question of collecting child support and not on the question of setting it.

  • United Kingdom Who owns the boundary wall and who pays to repair it: 4 civil codes, and 3 systems with no rule at all

    Party Wall etc. Act 1996

    Party walls in England and Wales are governed by the Party Wall etc. Act 1996, which is not in this corpus — and which in any event works differently from the four codes above: it regulates notices, awards and surveyors for works affecting a party wall rather than presuming who owns it. Ownership itself comes from the conveyance and from the facts on the ground. The lookup returned nothing from any Act the corpus does hold.

  • France Who pays for the roof and the lift: shared building costs in four legal systems

    Loi du 10 juillet 1965

    The textbook case of an answer living outside the code. French co-ownership of a building is the loi n. 65-557 of 10 July 1965, a free-standing statute; the Code civil says nothing about a syndicat de coproprietaires, a reglement de copropriete or a repartition of charges. A lookup across the whole Code civil returned no article with a page - correctly, because there is nothing there to return.

  • Deutschland Who pays for the roof and the lift: shared building costs in four legal systems

    Wohnungseigentumsgesetz

    The same, and less widely known outside Germany: German condominium is the Wohnungseigentumsgesetz, not the BGB. The lookup did return §§ 741 and 745 on the Bruchteilsgemeinschaft, which look plausible to a non-specialist and are the wrong body of law - a fractional community of co-owners is not Wohnungseigentum, and the WEG has its own rules on Kostenverteilung and Beschlusskompetenz. Both are left out rather than published as a false equivalent.

  • California Who pays for the roof and the lift: shared building costs in four legal systems

    Davis-Stirling Act

    California common-interest developments are governed by the Davis-Stirling Common Interest Development Act, Civil Code §§ 4000 and following, which has no pages in this corpus. The lookup offered §§ 1430-1432 and 1468, none of which is a page and none of which is the operative law for an HOA assessment.

The courts answer it

16 of 39

No statute governs the point, and none is needed: the rule is judge-made. Negligence, private nuisance, Rylands v Fletcher, abatement, a common-law debt, deceit, caveat emptor — all of these are law, and none of them is in a code to quote.

  • New York Noise from the neighbours: what the law says in seven countries

    Private nuisance; NYC Noise Code

    New York has no noise or nuisance provision in the Consolidated Laws. Private nuisance in New York is common law, developed by the courts rather than enacted, and the decibel limits and quiet hours people actually cite are the New York City Noise Code in title 24 chapter 2 of the Administrative Code, which is municipal law and outside this corpus. A lookup across the whole of the Consolidated Laws for this problem returned nothing, which is the correct answer rather than a gap in the corpus.

  • United Kingdom Someone's child damaged my property: what the law says in six jurisdictions

    The parent's own negligence

    The most interesting absence in this comparison, because it is the law rather than a missing page. In England a parent is not vicariously liable for a child's torts at all. Liability arises only where the parent was themselves negligent — in supervising, or in putting something dangerous in a child's hands — and that is a common-law negligence claim, not a statutory provision. A lookup over the Acts this section carries returned nothing, which is the correct answer rather than a gap.

  • United Kingdom The seller knew about the defect and said nothing: what the law says in 7 jurisdictions

    Caveat emptor; Misrep. Act 1967

    Caveat emptor survives on the sale of a house in England and Wales: there is no statutory warranty of condition and no general duty on the seller to volunteer what he knows. The buyer's routes are a survey, the replies given to pre-contract enquiries, and the Misrepresentation Act 1967 where a reply was untrue — and neither the 1967 Act nor the conveyancing practice around enquiries is in this corpus. The lookup returned nothing.

  • United Kingdom I lent a friend money with nothing in writing: what the law says in five jurisdictions

    A common-law debt

    A simple loan in England and Wales is a common-law debt, with no statutory provision creating or governing it. The Acts this section carries — the Children Act 1989, the Environmental Protection Act 1990, the Housing Act 1988, the Landlord and Tenant Act 1985, the Matrimonial Causes Act 1973, the Partnership Act 1890 and TOLATA 1996 — contain nothing on lending, and England's own writing requirement for guarantees sits in the Statute of Frauds 1677, which is not among them.

  • United Kingdom Sold as seen: the second-hand car that broke down, in four civil codes and three common-law systems

    Satisfactory quality in England and Wales is s. 14 of the Sale of Goods Act 1979 and, for consumer sales, the Consumer Rights Act 2015 - neither of which is in this corpus. Even if they were, neither would help here: the implied term as to satisfactory quality applies where goods are sold in the course of a business, so a purchase from a private seller falls outside it. The lookup returned nothing, and that is the right answer twice over.

  • California Sold as seen: the second-hand car that broke down, in four civil codes and three common-law systems

    Fraud, not warranty

    A private used-car sale in California carries no implied warranty of quality. The buyer's route is deceit, and the lookup found precisely that - §§ 1572, 1709 and 1710 on fraud. That is a different cause of action with a different element set: the buyer must prove a misrepresentation or a concealment and the seller's state of mind, where the four civil codes impose liability without either. California is therefore recorded as absent from the warranty cluster and present in the separate comparison on a seller who hid a defect.

  • New York Sold as seen: the second-hand car that broke down, in four civil codes and three common-law systems

    Fraud, and the contract

    The same position. Nothing in the New York Consolidated Laws pages answers a private used-goods sale; the used-vehicle warranty statute, Vehicle and Traffic Law s. 417, applies to dealers only. A New York buyer from a private seller is left with fraud and with whatever the contract itself says.

  • New York The builder did the work badly and will not come back: what the law says in 7 jurisdictions

    Breach of contract

    New York has no construction-defect statute among these pages. The lookup found GOL § 5-322.1, which voids indemnity clauses in construction contracts. It is a real and useful section, and it answers a different question: who bears the risk between the parties to a building contract, not what an owner may demand when the work is bad.

  • United Kingdom The neighbour's tree hangs over my garden: what the law says in four countries

    Abatement: common-law self-help

    Cutting back an overhanging branch in England and Wales is abatement, a common-law right of self-help. There is no section on it, so there is nothing to reproduce verbatim and nothing to compare. A lookup over the Acts this section carries answers with the statutory nuisance regime of the Environmental Protection Act 1990, which does not reach overhanging vegetation.

  • California The neighbour's tree hangs over my garden: what the law says in four countries

    Abatement, at common law

    Self-help abatement is common law in California too. The corpus does hold a real and closely related section — Civil Code § 3346, which has its own page — but it answers the opposite question: the damages, potentially trebled, payable by someone who injures a neighbour's tree. It is what you consult before cutting, not the authority to cut.

  • New York The neighbour's tree hangs over my garden: what the law says in four countries

    Nothing statutory. The New York corpus behind these pages covers the Domestic Relations, General Obligations, Partnership and Real Property Laws, and none of them contains an encroaching-vegetation provision; the lookup returned nothing rather than stretching a section that was there.

  • United Kingdom Water coming through the ceiling from the flat above: what the law says in 7 jurisdictions

    Negligence, nuisance, Rylands

    There is no Act of Parliament on water escaping between flats. A leak from upstairs is negligence, private nuisance or Rylands v Fletcher, all developed by the courts. The statutes the lookup reached for — LTA 1985 s. 11 and EPA 1990 s. 79 — answer the different question of a tenant against a landlord, or of a statutory nuisance against a local authority, not of one flat owner against another.

  • California Water coming through the ceiling from the flat above: what the law says in 7 jurisdictions

    Negligence

    California has a general duty clause, Civ. Code § 1714, and a nuisance definition, § 3479, and neither is a rule about escaping water. They set the frame in which a negligence claim is argued; they do not decide who bears the loss when a pipe fails.

  • New York Water coming through the ceiling from the flat above: what the law says in 7 jurisdictions

    Common-law negligence

    Same. The statute the lookup produced, RPL § 235-b, is the warranty of habitability, which the § 235-b page itself points out speaks only to the landlord's obligation under the lease: 'If a neighbor's plumbing caused the damage, § 235-b still speaks only to the landlord's obligation.' Neighbour against neighbour is common-law negligence.

  • California Who owns the boundary wall and who pays to repair it: 4 civil codes, and 3 systems with no rule at all

    The deed, or an easement

    There is no California code section presuming a boundary wall to be shared. Party-wall rights come from the deed, from an easement, or from common law, and the lookup returned nothing. Where a civil-law neighbour can start from a statutory presumption, a Californian one starts from the title documents and whatever the parties or their predecessors agreed.

  • New York Who owns the boundary wall and who pays to repair it: 4 civil codes, and 3 systems with no rule at all

    The deed, or an easement

    The same. New York has no statutory presumption of party-wall ownership in the Consolidated Laws pages, and the lookup returned nothing. Party-wall rights in New York are typically created by deed or by an easement recognised at common law, and disputes are argued from those documents rather than from a code article.

No page written yet

2 of 39

The provision is in the corpus these pages are built from and nobody has written it up. This is the one kind that is our gap rather than a finding, and it is listed so it can be closed.

  • New York Separated parents who cannot agree where the children live: what the law says in six jurisdictions

    DRL § 240

    New York decides custody under Domestic Relations Law § 240 and the Family Court Act. DRL § 240 is in the corpus these pages are built from — the gap here is a page, not a law. The New York pages reach § 241 (withholding visitation and maintenance) and § 72 (grandparent visitation and custody) but not § 240 itself, so New York cannot be listed as a member without a link to a page that does not exist. A page on DRL § 240 would close this.

  • Italia I lent a friend money with nothing in writing: what the law says in five jurisdictions

    Cod. civ. artt. 1813-1820

    Not a gap in the law but a gap in the pages, and the only one of its kind in this comparison. The Italian mutuo is art. 1813 of the Codice Civile — "il contratto col quale una parte consegna all'altra una determinata quantita' di danaro o di altre cose fungibili, e l'altra si obbliga a restituire altrettante cose della stessa specie e qualita'" — and it is in the corpus these pages are built from, along with arts. 1814, 1816, 1817 and 1820. No page has been written for any of them, so listing Italy here would mean a link to nothing. It is worth writing.

The label sorts the note; the note is the finding. Both are shown together everywhere, because "the courts decide this one" and "the rule is in an Act we do not carry" are different facts, and neither of them is "there is no rule".

What each collection actually holds

Page counts and how they fall across each section's own themes. The themes are not a shared taxonomy and are not forced into one: Italy groups by condominio, New York by which of four Consolidated Laws a section sits in. What is comparable is the shape.

Italia Codice Civile

3024 pages · 17 of 20 problems answered

  • Vicini di casa e confini 8

  • Condominio 11

  • Beni in comune 3

  • Possesso e usucapione 4

  • Affitto e locazione 6

  • Contratti e inadempimento 9

  • Vendita, lavori e difetti 5

  • Danni e responsabilità 8

  • Famiglia, figli e mantenimento 7

  • Eredità e successioni 7

  • Altri articoli 2956

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France Code civil

2847 pages · 16 of 20 problems answered

  • Voisinage et limites de propriété 17

  • Biens en indivision 3

  • Location et bail 7

  • Contrats et inexécution 10

  • Vente, travaux et malfaçons 7

  • Responsabilité et dommages 5

  • Famille, enfants et pension 8

  • Succession et héritage 5

  • Délais et prescription 5

  • Autres articles 2780

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Deutschland BGB

2452 pages · 19 of 20 problems answered

  • Nachbarn und Grundstücksgrenzen 9

  • Besitz und verbotene Eigenmacht 3

  • Gemeinsames Eigentum 4

  • Miete und Wohnung 12

  • Kauf und Mängel 8

  • Verträge, Verzug und Verjährung 6

  • Handwerker und Baumängel 5

  • Schadensersatz und Haftung 9

  • Familie, Kinder und Unterhalt 7

  • Erben und Pflichtteil 7

  • Weitere Vorschriften 2382

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España Código Civil

1874 pages · 19 of 20 problems answered

  • Vecinos y lindes 13

  • Bienes en común 8

  • Alquiler y arrendamiento 9

  • Contratos e incumplimiento 11

  • Compraventa, obra y vicios 6

  • Daños y responsabilidad 7

  • Familia, hijos y alimentos 9

  • Herencia y sucesiones 7

  • Otros artículos 1804

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United Kingdom UK legislation

745 pages · 9 of 20 problems answered

  • Children and parenting 9

  • Divorce and money 9

  • Renting a home 11

  • Repairs and service charges 13

  • Noise, smells and nuisance 4

  • Business partners 11

  • Co-owned property 5

  • Other provisions 683

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California California law

67 pages · 11 of 20 problems answered

  • Renting a home 15

  • Contracts and agreements 14

  • Injury, deceit and reputation 13

  • Neighbours, animals and nuisance 8

  • Family and property 12

  • Business partners 5

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New York New York law

64 pages · 10 of 20 problems answered

  • Renting a home 24

  • Condominiums and common charges 8

  • Divorce, support and children 9

  • Contracts and debts 7

  • Business partners 6

  • Buying, selling and owning land 6

  • Injury and liability 4

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This page maps provisions of several legal systems and links to the official text of each. It is not legal advice, it does not tell you which country's law governs your situation, it does not say which system would be better for you, and it takes no account of the circumstances of your case. For a live dispute, consult a qualified lawyer in the jurisdiction concerned.

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