Geoffrey Samuel law, should also act as the meeting point where comparative law, legal history and legal theory come together to investigate questions of harmonisation. Without such theoretical work, harmonisation will only ever operate at the level of les mots and this will mean that the European jurist will need not just his or her electrical adapter when crossing borders but also the legal equivalent of such a symbol of non-harmonisation. At the moment that equivalent is the rule. But, like the adapter, when the difference between systems is great, such a symbol of non-harmonisation, as useful as it may be, will simply prove to be dangerous. 170
RkJQdWJsaXNoZXIy MjYyNDk=