part vii • legal history and legal science • lena foljanty it in terms of the own universe, which he exemplifies by showing how the foundations of the Islamic religion were translated in an eighteenth-century Bengal text. Muhammad was equated with Hindu deities, the basis of this translation being not an abstract and universal concept, but rather the experience-based imagination of the audience: ‘Dharma who resided in Baikuntha was grieved to see all this. He came to the world as Muhammadan … [and] was called Khoda … Brahma incarnated himself as Muhammad, Visnu as Paigambar and Civa became Adamfa (Adam).’10 The lack of a universal tertiumis obvious in Chakrabarty’s example. The translation does not even pretend there is one – a transparency that shows how translation, and by extension comparison, work by mediating directly between two worlds of experience. The dilemma with any comparison is that we have to reduce complexity: we have to state equivalences, we have to create certain entities to be compared, even though we know about the nuances, fluidities, and pluralities. Should we avoid comparative research design, focusing more on intercultural entanglement as the current global turn suggests? My answer to this is clear. We have to engage in comparisons. Lawrence Friedman and Heikki Pihlajamäki emphasize in the present volume that not only differences but also similarities can be meaningful in comparative research. They broaden our understanding of the world’s legal landscape and inspire us to think of new explanations.11 As part of a research project at the Max Planck Institute for European Legal History in Frankfurt, three PhD students and I are working on a comparative framework that is alert to the translational character and the dilemmas of comparison, studying transformation processes in late nineteenth-century and early twentieth-century Japan, China, and the Ottoman Empire. Even though not colonized, all three countries set out 10 Chandra Sen, History of Bengali Language and Literature (1911), quoted in Dipesh Chakrabarty, Provincializing Europe: Postcolonial Thought and Historical Difference (Princeton: PUP, 2000), 82. 11 See also the recent volume by Olivier Moréteau, Aniceto Masferrer & Kjell Å Modéer (eds.), Comparative Legal History (Cheltenham: Edward Elgar, 2019) and the contributions to American Journal of Comparative Law(edition ‘Symposium legal history and comparative law’, ed. Thomas Duve), 66/4 (2018), 727 ff. 362
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