Seven legal systems, placed by where each keeps its answers
All seven answer all twenty of these everyday questions. What differs is where each keeps the answer: in the code, in a statute beside it, or with the courts. That gives every system a twenty-place profile, and two of them sit close together here when their profiles match. It is a map of how law is written down, not of how much of it there is — and nothing on it is placed by hand.
The map
Distance is difference. A line between two systems is drawn when they put the answer in the same place often enough; the heavier it is, the more of the twenty they treat alike. The four civil codes gather because they codify; the three common-law sections sit apart because much of their law is judge-made. Select any system, or any line, to see exactly which problems put it there.
Select a circle for one system, or a line for a pair. Press Escape to clear.
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The four civil codes sit together because they write nearly the same set of these answers into a code. The three common-law sections sit apart, and less tightly together, because more of what they answer with is judge-made — which is a difference in how the law is kept, not in whether there is any. Select one to see the evidence rather than the summary.
Every pair, as a number
The same twenty-one measurements the map is drawn from, before they were flattened into a picture. Select a cell for the pair.
| Italia | France | Deutschland | España | United Kingdom | California | New York | |
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What the two directions are made of
The map has no axes of its own — it is a projection, and it could be rotated without changing a single distance. But the spread along each direction is driven by particular problems, and naming them is more useful than labelling the axes with a guess. These are the problems on which the systems most sharply part company about where the answer belongs.
The wider direction carries 57% of the spread
- 4/7 Sold as seen: the second-hand car that broke down, in four civil codes and three common-law systems
- 4/7 The builder did the work badly and will not come back: what the law says in 7 jurisdictions
- 4/7 The neighbour's tree hangs over my garden: what the law says in four countries
- 4/7 The other parent stopped paying: child maintenance in four civil codes
- 4/7 Water coming through the ceiling from the flat above: what the law says in 7 jurisdictions
The number is how many of the seven answer that problem with a provision.
The narrower direction carries 21% of the spread
- 5/7 I lent a friend money with nothing in writing: what the law says in five jurisdictions
- 6/7 Someone's child damaged my property: what the law says in six jurisdictions
- 6/7 The seller knew about the defect and said nothing: what the law says in 7 jurisdictions
- 5/7 The landlord kept the deposit: how five legal systems decide who was right
- 6/7 Who stays in the family home: separation and the house in six legal systems
The number is how many of the seven answer that problem with a provision.
How this was measured, and what it is not
Three of the steps below are choices rather than facts. They are written out because a map like this is only worth reading if you can see what would move it.
- What counts as agreeing
- Two systems are alike on a problem when they keep the answer in the same place: both in the code, or both outside it for the same recorded reason — both leaving it to the courts, or both to special legislation. Outside the code for different reasons counts as half. We also scored it the other way — in the code or not, reasons ignored — and it moves three of the twenty-one pairs, by at most 0.08. The picture does not change, so there is no toggle for it.
- What was left out
- A cell where the provision exists in the corpus and nobody has written the page yet is dropped from that pair rather than scored. It is a fact about this site, not about the legal system, and folding our own backlog into a measurement of law would be a quiet lie. Every pair shows how many of the twenty it was scored on.
- What the flattening costs
- The profiles have twenty dimensions and the page has two. The placement is classical multidimensional scaling, not a force layout, so the distances are the measurement rather than an illustration of it — but they are an approximation, and the two directions carry 77% of the spread. On the twenty-one pairs, a drawn distance is out by 0.11 on average and by 0.33 at worst, against distances that run from 0.22 to 0.87. Both axes are drawn to one scale; the picture is never stretched to fill the frame.
- What this does not measure
- Not the similarity of legal systems, and above all not how much law a place has. Every one of these seven answers every one of these twenty problems. England and Wales fills nine of the twenty cells and answers all twenty — the rest is negligence, private nuisance, Rylands v Fletcher, abatement, a common-law debt: law that is decided rather than enacted, and so has no article to quote. Reading a thin column as a thin body of law is the easiest mistake to make on this page and it would be exactly wrong. Twenty everyday disputes are also only twenty everyday disputes, and these are seven particular collections with particular holes — England is represented here by seven Acts, New York by four of its Consolidated Laws. It is not a better or a worse place to bring a claim, nothing here predicts an outcome, and there is no ordering of any kind on this page.
That's the map. Now let's settle your problem.
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This page measures how often seven collections of legislation answer the same everyday problems, and links to the official text of each provision it names. It is not legal advice, it does not tell you which country's law governs your situation, it does not rank jurisdictions, and it takes no account of the circumstances of your case. For a live dispute, consult a qualified lawyer in the jurisdiction concerned.