Comparative Law Research

By Hester Swift

Hester Swift has been a Foreign and International Law Librarian at the Institute of Advanced Legal Studies, University of London, since 2007.

Published July/August 2025

(Previously updated by Paul Norman in August 2007, and by Hester Swift in February 2009, June/July 2013, June 2016, and in May/June 2021)

See the Archive Version!

1. What is Comparative Law?

The Cambridge Companion to Law explains that comparative law can mean a variety of things, including comparing different legal systems, examining legal transplants (the use of legal models from a foreign jurisdiction), and “exploring the relationship between law and society.”[1]

Many comparatists now use postcolonial, decolonial, interdisciplinary, and other non-traditional approaches.[2] Charles Fombad, director of the Institute for International and Comparative Law in Africa, has written that conventional comparative law, with its “Euro- and Americo-centric focus,” has no place in the law curriculum of African universities.[3] Lena Salaymeh and Ralf Michaels point out that “[t]he discipline of comparative law, as it exists today, is structured and dominated by the Global North.”[4] In Asia, scholars have begun to compare the region’s legal systems without reference to US or European law.[5] Nevertheless, conventional comparative law studies are still carried out,[6] and Jaako Husa sees a future in which “instead of abandoning traditional methods, new approaches are deployed alongside traditional ones.”[7]

Comparative law is a separate topic from conflict of laws and unification (or harmonization) of law, but all these subjects are closely related. Conflict of laws, also referred to as private international law, concerns national or domestic legal rules which are applicable in situations involving the law of another jurisdiction; this may be another country or, in the case of federations, another state. Unification of law is a process that grew out of the need to simplify conflict of law rules, often by international conventions, and has acted on both the national and international levels. The numerous uniform laws applicable in the United States, most notably the Uniform Commercial Code, are examples. For a much fuller discussion of harmonization and of uniform law resources, see Loren Turner’s Globalex article, Researching the Harmonization of International Commercial Law.

Comparative law scholars speak of “families” of legal systems, or of “traditions,” highlighting their historical development. The best-known distinction is that between the common law and the civil law traditions. Common law systems originated with English law; civil law systems have their foundations in Roman law but are generally based on codifications produced in Europe in the 19th Century, notably the French Civil Code of 1804 and the German Civil Code of 1900. The traditional classification of legal systems offered by David are Romano-Germanic, Socialist / Russian, Common law, and Religious/philosophical.[8] Zweigert and Kötz set out a somewhat different taxonomy: Romanistic, Germanic, Nordic, Anglo-American, Far Eastern, and Religious.[9]

In recent decades, there has been increasing interest in indigenous, or “chthonic” law. Glenn classified the world’s legal traditions as Chthonic, Talmudic, Islamic, Hindu, Asian, civil law, and common law.[10] Mattei, on the other hand, has proposed categories based on the principal source of legal norms: the rule of professional law, rule of political law, and rule of traditional law,[11] while Vernon Palmer calls mixed jurisdictions the “third legal family,” after common law jurisdictions and Roman-German jurisdictions.[12]

2. Books and Journals

2.1. Books

The Cambridge Handbook of Comparative Law, edited by Mathias Siems and Po Jen Yap, provides a concise overview of the subject. It was published by Cambridge University Press in 2024 and is deliberately global in scope.[13]

Ius Gentium: Comparative Perspectives on Law and Justice is a book series published by Springer with over a hundred volumes.

Other works include:

  • Casis, R.J., and Buban, A. R. A., (eds.), Asian Comparative Law, volume 1 (Institute of International Legal Studies, University of the Philippines Law Center, 2021, open access); a planned second volume will focus on comparisons with the law of the Philippines.
  • Glendon, M., et al, Comparative Legal Traditions: Text, Materials, and Cases on Western Law, 4th ed. (West Academic, 2015).
  • Glenn, H P. Legal Traditions of the World: Sustainable Diversity in Law, 5th ed. (Oxford University Press, 2014); the first edition won the International Academy of Comparative Law’s Canada Prize in 1998.
  • Husa, J., Interdisciplinary Comparative Law: Rubbing Shoulders with the Neighbours or Standing Alone in a Crowd (Edward Elgar, 2022).
  • Mancuso, S., and Fombad, C.M., Comparative Law in Africa: Methodologies and Concepts (Juta, 2015).
  • Menski, W., Comparative Law in a Global Context: The Legal Systems of Asia and Africa, 2nd ed. (Cambridge University Press, 2006).
  • Merryman, J.H. and Pérez-Perdomo, R. The Civil Law Tradition: An Introduction to the Legal Systems of Europe and Latin America, 4th ed. (Stanford University Press, 2018).
  • Palmer, V., ed., Mixed Jurisdictions Worldwide: The Third Legal Family, 2nd ed. (Cambridge University Press, 2012).
  • Reimann, M. and Zimmermann, R. (eds.), The Oxford Handbook of Comparative Law. 2nd ed. (Oxford University Press, 2019).
  • Samuel, G., An Introduction to Comparative Law Theory and Method (Hart, 2014).
  • Siems, M., Comparative Law. 3rd ed. (Cambridge University Press, 2022).
  • Smits, J., Husa, J., Valcke, C. and Narciso, M., Elgar Encyclopedia of Comparative Law, 3rd ed. (Edward Elgar, 2023).
  • Zweigert, K., and Kötz, H., Einführung in die Rechtsvergleichung, 3rd ed. (Mohr, 1996) / An Introduction to Comparative Law, transl. Tony Weir, 3rd ed. (OUP, 1998).

2.2. Journals

The following are a small selection of comparative law journals:

Thirty-eight comparative law journals are covered by the W&L Law Journal Rankings and many more are listed by Teresa Miguel and others, “Comparative Law: Academic Perspectives,” Appendix A, in The IALL International Handbook of Legal Information Management, Danner, R. A., and Winterton, J., (eds.), Ashgate, 2011 (open access version available from Yale Law School).

3. Organizations and Research Institutes

The International Academy of Comparative Law (IACL), founded at The Hague in 1924, holds the International Congress of Comparative Law every four years. Since 2008, it has also had regular thematic conferences looking at a particular topic from a variety of perspectives. The academy produces general, thematic, and national reports, which are issued by various publishers (see the IACL website).

The International Association of Legal Science (IALS), founded in Paris in 1950 and linked to UNESCO, seeks to use comparative law and other methods to advance the development of legal studies around the world. It holds congresses and symposia every few years. The International Encyclopedia of Comparative Law was published under the auspices of the association.

The World Society of Mixed Jurisdiction Jurists, established in New Orleans in 2002, promotes comparative research relating to mixed jurisdictions. It holds congresses every few years.

Juris Diversitas, started in 2007 at the Swiss Institute of Comparative Law, is an international, interdisciplinary association for comparative lawyers and researchers from other disciplines, including anthropology, history, and sociology. It holds periodic conferences and has a monograph series published by Routledge.

3.1. Selected Organizations and Institutes by Country

There is a fuller list of comparative law organizations and research centers in Appendices B and C to “Comparative Law: Academic Perspectives,” in The IALL International Handbook of Legal Information Management, Danner, R. A., and Winterton, J., (eds.), Ashgate, 2011 (Yale open access version); see also the American Society of Comparative Law’s list of foreign institutional members.

4. Foreign and Comparative Law Research Guides

5. Multi-jurisdictional Sources

  • International Encyclopedia of Comparative Law (Brill Publishing). Online title, the print edition, which started in 1971, ceased with installment 44, 2020.
  • International Encyclopedia of Laws: a Kluwer publication, print and online, covering around twenty-five areas of law across a range of jurisdictions. The component parts are also available as monographs, for example Tort Law in Poland.
  • Jurisclasseur droit comparé, French-language encyclopedia covering thirty-three jurisdictions, including North African countries and Senegal. Edited by Benoit le Bars, Joël Monéger, and Jean-Louis van Boxstael (LexisNexis France); on Lexis 360.
  • WorldLII (World Legal Information Institute): freely available full-text primary (and some secondary) legal material for more than 120 jurisdictions; also has links to foreign law websites.

5.1. Regional sources

  • Antons, C., (ed.), Routledge Handbook of Asian Law (Routledge, 2017).
  • Commonwealth Caribbean Law: book series published by Routledge.
  • Gazettes for Africa – Gazettes.Africa: freely available African official gazettes, containing legislation and other material.
  • International and Comparative Law in the Asia Pacific: Springer book series.
  • N-Lex: search interface covering the free national legislation databases of the twenty-seven EU member states; also gives links to other national legislation sites.
  • Ndulo, M., and Emeziem, C., (eds.), Routledge Handbook of African Law, (Routledge, 2022).
  • Pechota, V. (ed.), Central and Eastern European Legal Materials (Juris Publishing, 1990-): compilation of key legislation from the region, translated into English; multi-volume looseleaf title; chapters also available in pdf format.
  • Routledge Law in Asia: book series.

Multinational Sources Compared: A Subject and Jurisdiction Index, compiled by Alena L. Wolotira and Sherry L. Leysen, is a directory of print and online sources that cover particular areas of law across a range of jurisdictions. It is available on the HeinOnline service.

Research Handbooks in Comparative Law Series, edited by Francesco Parisi and Tom Ginsburg, devotes each volume to a particular area of law, covering jurisdictions around the world (Edward Elgar, 2011- ).

See also Jennifer Allison’s Globalex article, Foreign law: subject law collections on the web.

Selected subject-focused titles are listed below:

Constitutional Law

  • African Constitutions: constitutional texts, country reports and related publications, freely available from the Institute for International and Comparative Law in Africa.
  • Blaustein, A. P., Flanz, G. H., Grote, R. and Wolfrum, R., Constitutions of the countries of the world (OUP, 1971- ): updated constitutional texts, chronologies and annotated bibliographies. Multi-volume looseleaf / online resource.
  • Bui, N.S., and Malagodi, M. (eds.), Asian Comparative Constitutional Law (Hart Publishing, 2023- ): 4 volumes planned, 2 published.
  • Constitute: free global database of constitutions provided by the Comparative Constitutions Project, University of Texas at Austin.
  • Dixon, R., and Ginsburg, T. (eds.), Comparative Constitutional Law in Asia, (Edward Elgar, 2014).
  • Dixon, R., and Ginsburg, T. (eds.), Comparative Constitutional Law in Latin America (Edward Elgar, 2017).
  • Dixon, R., Ginsburg, T., and and Abebe, A. (eds.), Comparative Constitutional Law in Africa, (Edward Elgar, 2022).
  • Grote, R., Lachenmann, F., and Wolfrum, R., (eds.), Max Planck Encyclopedia of Comparative Constitutional Law, (OUP, 2017 – ); online resource.
  • Oxford Constitutions of the World: OUP e-resource providing current constitutions, bibliographies and commentary.
  • World Constitutions Illustrated, part of the HeinOnline service: current and historical constitutions, bibliographies and links to commentary.

Criminal Law

  • Information System for Comparative Criminal Law (Informationssystem für Strafrechtsvergleichung): freely available country reports covering the general criminal law of twenty-five jurisdictions, many in English, others in German; provided by the Max Planck Institute for the Study of Crime, Security and Law.

Family and Inheritance Law

  • Bring, M. (ed.), International Survey of Family Law (Martinus Nijhoff/Intersentia, c.1996- ): annual review of global developments, compiled by the International Society of Family Law.
  • Commission on European Family Law: country reports and other material on European family law. The Commission’s book series, European Family Law, is published by Intersentia.
  • Ferid, M., Firsching, K. and Hausmann, R., Internationales Erbrecht (International Inheritance Law), published by Beck. Arranged by jurisdiction, with commentary and legislative texts; multi-volume looseleaf/online resource, in German.
  • Henrich, D., et al (eds.), Internationales Ehe- und Kindschaftsrecht (International Marriage and Child Law), published by Verlag für Standesamtswesen. German-language title compiling laws and commentary, arranged by jurisdiction; the legislation is usually in the vernacular as well as German; multi-volume looseleaf/online resource.

Labour Law

  • Blanpain, R., (ed.), International Encyclopaedia for Labour Law and Industrial Relations, published by Kluwer, looseleaf and online; part of the International Encyclopedia of Laws.
  • International Labour Organization, Normlex: a free global database of labour and social security laws and standards.

Intellectual Property

  • Campbell, D. (ed), World Intellectual Property Rights and Remedies: Laws with Commentary (Thomson Reuters, 2024- ): multi-volume print set, also available on Westlaw. Contains commentary and English translations of key legislation for more than fifty jurisdictions.
  • WIPO-Lex: open access database of domestic laws and treaties relating to intellectual property (World Intellectual Property Organization).
  • Cotreau, W.J., Sinnott, J.P., and Sinnott, J.M. (eds.), World Patent Law and Practice, (LexisNexis/Matthew Bender, 1975 -): multi-volume looseleaf containing laws and commentary for more than 200 jurisdictions.

Tax and Commercial Laws

  • IBFD Tax Research Platform: this online resource from the International Bureau of Fiscal Documentation includes guides to tax systems of the world.
  • RIA’s Worldwide Tax Law service provides tax and commercial laws of over ninety jurisdictions, in English. Available online via Thomson Reuters’ Checkpoint platform.
  • Tinsley, P., and Campell, D. (eds.), Digest of Commercial Laws of the World (Thomson Reuters, 2024- ): multi-volume print title, also on Westlaw; covers more than sixty jurisdictions.

Trusts

  • Hauser, Barbara R., and Kaplan, A., Trusts in Prime Jurisdictions, 5th ed. (Globe Law and Business, 2019): outlines the law of trusts in twenty-four jurisdictions around the world.
  • Ying, K.L., and others (eds.), Asia-Pacific Trusts Law, (Hart, 2021- ): multi-volume work covering seventeen jurisdictions (vol. 3 forthcoming, May 2025).

[1] Mauro Bussani and Ugo Mattei, eds., Cambridge Companion to Comparative Law (Cambridge University Press, 2012) p.3.

[2] Jaako Husa, ed., A Research Agenda for Comparative Law (Edward Elgar, 2024) p.5.

[3] Charles Fombad, ‘Comparative Research in Contemporary African Legal Studies’ (2018) 67 J Legal Educ 984, 986.

[4] Lena Salaymeh and Ralf Michaels, ‘Decolonial Comparative Law: A Conceptual Beginning’ (2022) 86 Rabels Z 166, 167 (open access via SSRN). In 2019, Salaymeh and Michaels established a long-term project at the Max Planck Institute for Comparative and International Law, Hamburg.

[5] Gary F. Bell, ‘The State of Comparative Law and Its Teaching in Asia: An Introduction’ (2019) 14 As JCL S3-S4.

[6] Jaako Husa, ‘Traditional Methods,’ in Mathias Siems and Po Jen Yap (eds.), Cambridge Handbook of Comparative Law, p.16

[7] Ibid, p.30.

[8] René David, Camille Jauffret-Spinosi, and Marie Gore, M., Les grands systèmes de droit contemporains, 12th ed., Dalloz, 2016. This classic work has been translated into numerous languages; an English version of the 6th edition of 1974 was published by Sweet and Maxwell as Major Legal Systems in the World Today, 3rd edition in 1985 (out of print).

[9] Konrad Zweigert and Hein Kötz, Introduction to Comparative Law, 3rd ed., Oxford University Press, 1998.

[10] H. Patrick Glenn, Legal Traditions of the World: Sustainable Diversity in Law, 5th ed., OUP, 2014, p.62.

[11] Ugo Mattei, ‘Three patterns of law: taxonomy and change in the world’s legal systems,’ (1997) 45 American Journal of Comparative Law 5.

[12] Vernon Palmer, ed., Mixed jurisdictions worldwide: the third legal family. 2nd ed. Cambridge University Press, 2012.

[13] ‘Preface’ p. xvii.