The same argument, in seven legal systems
Twenty problems that arrive in the same words everywhere and are answered by different provisions. Each comparison states the problem, then what these systems agree on, then exactly where they part company — and links to the official text of every provision it names.
Nothing here restates a statute from memory: the words of the law are on the country pages, quoted from the licensed corpus. 20 comparisons.
The sections compared
7 jurisdictions
The landlord will not repair: damp, mould and no heating in 7 jurisdictions
Mould, rising damp and a dead boiler, and the landlord does nothing. All seven jurisdictions oblige him to keep the home habitable. What differs is what the tenant may do about it: automatic rent reduction in Germany, capped repair-and-deduct in California, a court order in England.
6 jurisdictions
Locked out: the landlord changed the locks and cut the power, in 7 jurisdictions
Locks changed while you were at work, belongings in the basement, electricity off, no court order. Italy, Germany and Spain put you back in first and argue later. England and California price the wrong instead. New York makes it an offence. France abolished the remedy in 2015.
6 jurisdictions
Noise from the neighbours: what the law says in seven countries
Italy, France, Germany, Spain, England, California and New York compared on neighbour noise: the threshold test, who you sue, whether complying with the noise limits protects you, and what you actually get.
6 jurisdictions
Separated parents who cannot agree where the children live: what the law says in six jurisdictions
Italy, France, Germany, Spain, England and California all decide by the child's interest and none of them prescribes a calendar. They differ on the starting point, on whether the court gets a checklist, and on whether a child can say no.
6 jurisdictions
Someone's child damaged my property: what the law says in six jurisdictions
France holds parents liable de plein droit, Germany only for their own failure to supervise, and California and New York cap the bill at $25,000 and $5,000. England has no rule at all — and that is the finding, not a gap.
6 jurisdictions
The seller knew about the defect and said nothing: what the law says in 7 jurisdictions
You bought a home and found the leak the seller knew about. Italy, France, Germany and Spain give a warranty that works without proving what the seller knew. California makes you prove he knew. New York gives you a form. England gives you caveat emptor.
6 jurisdictions
The tenant has stopped paying and will not leave: what the law says in six jurisdictions
Italy, Germany, Spain, England, California and New York all send a landlord to court to recover a home. They divide sharply on whether the grounds are a closed statutory list, how much arrears it takes, and who pays for the months the tenant stays on.
6 jurisdictions
Who stays in the family home: separation and the house in six legal systems
Italy, France, Germany, Spain, England and New York compared on the family home after a separation - occupation versus ownership, the children's role, the deadlines nobody reads, and the one system that can transfer the house outright.
5 jurisdictions
A dog bit someone: what the law says in five countries
Italy, France, Germany, Spain and California all make the keeper of an animal answer for a bite without proof of carelessness. They disagree about who counts as the keeper, what the escape route is, and whether the rule covers anything other than a dog and a bite.
5 jurisdictions
I lent a friend money with nothing in writing: what the law says in five jurisdictions
France, Germany and Spain have an article about the loan itself; California and New York have no loan article at all, only a list of promises that need writing — and a loan repayable within a year is on neither list.
5 jurisdictions
Siblings inherited the house and one will not sell: what the law says in 7 jurisdictions
Three siblings inherit the family home, one lives in it and refuses to sell. In Italy, France, Germany and Spain nobody can be forced to stay in an undivided estate and any co-heir can demand the split. In England the court decides — and can say no.
5 jurisdictions
The landlord kept the deposit: how five legal systems decide who was right
France, Germany, Spain, California and New York compared on security deposits: who bears the burden of proof, whether there is a deadline, what wear and tear means, and what the landlord loses by getting it wrong.
4 jurisdictions
Sold as seen: the second-hand car that broke down, in four civil codes and three common-law systems
Italy, France, Germany and Spain compared on hidden defects in a private sale - the fault question, whether 'sold as seen' survives, the clocks that run from delivery rather than discovery, and why England, California and New York offer nothing at all.
4 jurisdictions
The builder did the work badly and will not come back: what the law says in 7 jurisdictions
Cracked tiles, a leaking bathroom, a builder who has stopped answering. Italy, France, Germany and Spain all give the owner a right to have it done again and a long guarantee on structural work — but only Germany lets you take the money up front. England, California and New York have no code answer.
4 jurisdictions
The landlord wants to raise the rent: four systems that limit it, and three civil codes that say nothing
Germany, England, California and New York compared on residential rent increases - consent, market comparison, percentage caps and notice periods - and why the Italian, French and Spanish civil codes have no answer at all.
4 jurisdictions
The neighbour's tree hangs over my garden: what the law says in four countries
Italy, France, Germany and Spain all let you cut invading roots yourself and all stop you cutting the branches — except Germany, which lets you cut them after a deadline. The planting-distance rules behind them are four different systems.
4 jurisdictions
The other parent stopped paying: child maintenance in four civil codes
Italy, France, Germany and Spain compared on child maintenance - the two variables that set the amount, why the duty does not stop at eighteen, the only code with a published scale, and why England, California and New York are missing.
4 jurisdictions
Water coming through the ceiling from the flat above: what the law says in 7 jurisdictions
Water from the flat above ruined your ceiling and the neighbour says it is not his fault. Italy, France, Germany and Spain each answer with a different rule on fault and proof; England, California and New York have no statute at all.
4 jurisdictions
Who owns the boundary wall and who pays to repair it: 4 civil codes, and 3 systems with no rule at all
The wall between two gardens is crumbling and each neighbour says it belongs to the other. Italy, France, Germany and Spain all presume it is shared — but they presume different things, rebut it differently and split the bill differently. England, California and New York have no statute.
4 jurisdictions
Who pays for the roof and the lift: shared building costs in four legal systems
Italy, Spain, England and New York compared on service charges and common expenses - the ground-floor owner and the lift, whether you can opt out, and why France, Germany and California answer this outside the civil code.
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The pages in this section compare legislation in general terms and link to the official text of each provision. They are not legal advice, they do not decide which country's law governs a situation, and they take no account of the circumstances of any individual case. For a live dispute, consult a qualified lawyer.