vin Moreen er, legal transplants are ine\ itahle. Sinee the later Roman empire they have been a major, it ne)t always the main, factor in legal change in the western world.’" England is no exception. Nor is the United States. Nor is (^ebec, even with its differences from the other Provinces. I'he real issue is whether there should he a deliberate concerted effort, spear-headed perhaps by academics, to create a common law. Codification presents comparatixe legal historians with insights into legal dexelopment. I have mentioned d'urkcw and Armenia as examples of extreme borrowing from codes of other countries. But codification prox ides other lessons. Ex en xvithin one nation xx here different parts of the country haxe different laxv codification can prox ide a x ery great deal of unity. Witness the great success of, and high regard for, the Erench code civil (1804^ xvhere prex iouslx' in Erance there had been a multiplicitx’ of local customs. Eikexvise the great success of the German Burgcrlicbcs Gesetzhucb {v)oo) when rnanx' parts of the countrx’ had operated under different codifications, xvhether the Prussian Allgcmciju's (1-94), Saxonx 's Riirgerliebes Gesetzbiicb fiir (ids Königreieb Sdcbscfi (186^-), (xr ex en the I'rench code civil. Or exen the mediaex al Sdcbscuspicgcl! Dix ersitx" has its benefits,” hut in laxv also its draxvbacks. \\ here laxv in different states differs, xet is inxolved in some issue, xvhich laxx is to be applied presents insuperable difficulties.'' Cionflict of 30 For infiltration of foreign law through legal scholarship see also Jan-Olof Sundell, 'German Influence on Swedish Private Law Doctrine 1870-1914,' Scandinavian Studies in Law 1991 (Uppsala), pp. 237ff. 31 Fromage in French and in France is not always the same as fromage in French and in France. Thank God! 32 See most recently Friedrich Juenger, The Problem with Private International Law(Rome, 1999; Centro di studi e ricerche di diritto comparato e straniero; Saggi, ecc. 37); Dieter Martiny, 'Is Unification of Family Law Feasible or Even Desirable?' in European Civil Code, pp. isiff. 118
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