The Law Merchant, a precursor to modern industrial law, emphasised the liberty to contract and alienability of property. As nationalism grew within the 18th and 19th centuries, the Law Merchant was incorporated into countries’ local law beneath new civil codes. In contrast to English widespread law, which consists of enormous tomes of case law, codes in small books are straightforward to export and straightforward for judges to apply. EU law is codified in treaties, however develops via de facto precedent laid down by the European Court of Justice.

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