British economist John Kay thinks that when it comes to legal system English law wins;
"English law is very widely used in financial services, even for transactions that have no other connection with England. English law gives much more freedom to write whatever contract the parties want than the civil law systems of many other countries. English judges, politically neutered, have been formalistic in enforcing the strict terms of contract, while courts in America pay more attention to the context of the transaction – the intentions of the parties and the reasonableness of the contract terms.This English combination of flexibility before the event and rigidity after it is attractive to many. English courts have also acquired a reputation for giving foreigners a fair crack of the whip. These competitive attractions of the English legal system have made City of London law firms large exporters of legal services."
But England does not appear to be a good place for rich people with troubled marriages.
Related Links:
- The American Legal System in Brief
- The Economics of Contract
- Why is Tort Law like Accounting?
- Accounting for Lawyers
- The latest Law Report podcast from Radio National; lively debate recorded at the recent Brisbane Ideas Festival which looks at how evolving notions about justice and progress might produce radical new strategies.
Criminal law in England is quite another matter.