[spockz]

I think this is more of an Anglo-Saxon vs rest of Europe distinction. In UK (and presumably US) the letter of the law is more important than the intent. In the rest of Europe the intent is more important than the exact letter.

In both cases it is up to the judiciary to make the trade-off/judgement.

[realusername]

That's pretty much the same in both systems, if anything the common law system is based even more on intent than civil law.

[Y_Y]

Anglo-Saxon? What has that to do with Common vs. Civil Law? Or is it a magic term like "Caucasian" or "Judeo-Christian" that just handwaves some psuedo-historical distinction for "us vs them"?

[kwhitefoot]

They are probably claiming that English Common Law differs from Code Napoleon, and Roman Law in general, in the way they claim. As someone else mentions, they have it backwards.