srciiLC or absciici.' ot clioicc. On rhis criterion alone, the I'urkish experience is a snhstantial and tliorough exjierience in 'reception."' 1 listoricallx', I'lirkisli academics had most ot their training in universities in the countries trom wliere the receptions came, d'he fitting ot all motlels to the I’urkish situation was indeed uiulertaken h\’ academics so trainetl. Language training and translations were extensiv e.In the earlv v ears of the Republic, Svv is.s, .Vustrian and Cierman academics also contributed to the new legal svstem as a conseipience ot historical accident and thus greatlv helped the imported svstem to take root. Rrotessors such as Schwartz, König, Neumark and 1 lirsch were giv en sanctuarv in I'urkev before the Second World War and held posts in furkish universities. Manv of their Turkish assistant lecturer translators later became intluential protes.sors in their own right. M\' own interest is pri\ ate law, and 1 wish onlv to insert a tew de tails that 1 have treated before: (i) The main draftsman ot the civ il code, .\lahmut f.sad Bozkurt, had stiulied law in Switzerland. I'hat was the law he knew, fhe general opinion of scln lars is that this tact is the mam reason tor the choice ot Swiss law tor the base ot the Turkish civ il code. (’) W hat was borrowed was nor just the Swiss codes, but their court decisions and academic opinion. What can be, and is, borrowed is not iust statutorv rules. (0 As Oriicii has indicated, there was a continuing relationship between Turkish law and luiropean codes: Kuropean professors were appointed to reach Turkish law (through interpreters); prospective furkish legal academics (and others) studied law in continental I'urope. ' V. But now wc have the civ il codes or drafts thereof'of the states of the former Sov iet Union. Xinetv seven percent of the draft of hook 2 of the new .Armenian civ il code, Obligations, is taken straight from the Russian civ il code. The draft is written in Russian, not in Armenian. My understanding is that the code will come into effect 19 Critical Comparative Law: Considering Paradoxes for Legal Systems in Transition (Deventer, 1999: Nederlandse Vereniging voor Rechtsvergelijking, no. 59) pp. 8if. 20 Critical Comparative Law, p. 84 21 For more detail, see Watson. Evolution, pp. i4ff. 1 1 1
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