RSK 2

nion. rhiis, tor instance we lia\ e Duranton, C.orso cii diritto civile sfcojido il rw//Vc/;v/;/c<’.r<’(Naples, i8;;2-uS44) in 22 xolumes. I'o come finallv to the idea ot a single code ot pri\ ate law tor the lAiropean Union. The drafting of such a code would be technicalK’ east', despite political difficulties, 'fhe statutory law would then he the same for all the nations. Hut what about differences of interpretation.' 1 bat e gi\ en sex eral e.xamples (d the ability of the lawyers of one countr\’ to take an e.xtreme interest in, and pay great attention to, the iuristic opinion and judicial decisions of another countr\' which has a related st’stem. \ (ainformity of interpretation will he a problem, hut one must not exaggerate. 1 ha\'e no doubt that legal scholars will scrutinize decisions in all of the countries of the IhU. \\ hen the\' notice differences, thew will write articles (e\ en hooks) suggesting the best approach for the future, \loreo\ er, the prix ate law of the countries of the U.U. is not all that different.^^ Not only that, hut it is possible to imagine some official system to attempt homologation. .\s one suggestion 1 would put forward a modified sx stem of the Scc^ttish uohilc officiiim. 'Fhere could he an lyU. high judicial hod\' that did not hear appeals. But when a decision in one country seemed out of line, or indicated problems, that body could of itself determine to look at the decisions in the \ arious independent nations. It could issue an opinion as to what it regarded as the best approach to the interpretation of the text of the code, perhaps e\ en supporting the aberrant decision. 24 See Walter van Gerven, 'The EC) Case Law as a Means of Unification of Private Law?' in European Civil Code, pp. 9iff. 114

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