Legal codes and constitutions: who copied whom
The French Civil Code of 1804 was copied across half the world. The German code reached Japan and Greece. The Swiss code was adopted almost whole by Turkey. Follow the great texts of law through time, and see how each one shaped the next.
Part of the Legal Families Atlas family of tools. Open any text to see what it was built on and what grew from it.
Six great families of borrowing
The French family
From the Napoleonic Code of 1804 through Italy, Spain, Latin America, the Middle East and Africa.
French Civil Code (Napoleonic Code) (1804) led to:
- 1808 Louisiana Digest of the Civil Laws
- 1855 Chilean Civil Code (Andrés Bello)
- 1865 Italian Civil Code of 1865
- 1889 Spanish Civil Code
- 1896 Japanese Civil Code
- 1925 Thai Civil and Commercial Code
- 1929 Civil Code of the Republic of China
- 1942 Italian Civil Code of 1942
- 1948 Egyptian Civil Code (Sanhuri)
- 1949 Civil Code of the Philippines
- 1951 Iraqi Civil Code
- 1966 Portuguese Civil Code
- 1976 Jordanian Civil Code
- 1985 UAE Civil Transactions Law
- 1991 Civil Code of Québec
- 1992 Dutch New Civil Code
- 1994 Civil Code of the Russian Federation
- 2000 Civil Code of Lithuania
- 2002 Brazilian Civil Code
- 2016 French contract-law reform
The German family
From the German Civil Code to Japan, Greece, Brazil, Thailand, Taiwan and the post-Soviet states.
German Civil Code (BGB) (1896) led to:
- 1896 Japanese Civil Code
- 1907 Swiss Civil Code (and Code of Obligations)
- 1925 Thai Civil and Commercial Code
- 1926 Turkish Civil Code
- 1929 Civil Code of the Republic of China
- 1940 Greek Civil Code
- 1942 Italian Civil Code of 1942
- 1966 Portuguese Civil Code
- 1992 Dutch New Civil Code
- 1994 Civil Code of the Russian Federation
- 1997 Civil Code of Georgia
- 2000 Civil Code of Lithuania
- 2002 Brazilian Civil Code
The Swiss branch
A small country's code that was adopted almost whole by Turkey.
The Egyptian family
The code of Sanhuri, copied across the Arab world.
The American constitutional family
The first written constitution, and those that followed it.
The Dutch branch
A modern code that served as a model for new codes after 1990.
Dutch New Civil Code (1992) led to:
The full timeline
48 texts
Roots: antiquity to the 1700s
c. 1750 BCE · Early law
Code of Hammurabi
Babylon
A collection of nearly three hundred laws carved on a stone pillar by the Babylonian king Hammurabi, covering trade, property, family and crimes.
529 to 534 · Early law
Corpus Juris Civilis (Justinian's Code)
Byzantine (Eastern Roman) Empire
The Emperor Justinian ordered Roman law to be gathered and organised into the Code, the Digest, the Institutes and later laws.
Shaped 4 later texts
1215 · Charters, declarations and treaties
Magna Carta
England
A charter agreed by King John and his barons, promising that the king himself must obey the law and that no free man should be punished without lawful judgment.
Shaped 1 later text
1689 · Charters, declarations and treaties
English Bill of Rights
England
An Act of Parliament that limited the power of the Crown, protected free speech in Parliament and banned cruel and unusual punishments.
Built on 1 earlier text · Shaped 2 later texts
The age of revolutions: 1776 to 1815
1787 (in force 1789) · Constitutions
Constitution of the United States
United States
The first written national constitution still in force. It sets up a federal government with three branches and divides power between the nation and the states.
Built on 1 earlier text · Shaped 3 later texts
1789 · Charters, declarations and treaties
Declaration of the Rights of Man and of the Citizen
France
A revolutionary statement that all people are born free and equal in rights, and that law is the expression of the general will.
Shaped 2 later texts
1791 · Charters, declarations and treaties
United States Bill of Rights
United States
The first ten amendments to the US Constitution, protecting freedoms such as speech, religion and fair trial.
Built on 2 earlier texts · Shaped 2 later texts
1804 · Civil codes
French Civil Code (Napoleonic Code)
France
One short, clear code covering persons, property and the ways property is acquired, including contracts. It replaced the patchwork of old local customs.
Built on 2 earlier texts · Shaped 10 later texts
1808 · Civil codes
Louisiana Digest of the Civil Laws
Louisiana (United States)
A civil code for the territory of Orleans, later Louisiana, drawing on French and Spanish law.
Built on 1 earlier text
1811 · Civil codes
Austrian General Civil Code (ABGB)
Austria
A civil code for the Habsburg lands, built on natural-law ideas and Roman law.
Built on 1 earlier text · Shaped 1 later text
The age of codification: 1816 to 1914
1844 · Civil codes
Serbian Civil Code
Serbia
Serbia's first civil code, adopted in the principality of Serbia.
Built on 1 earlier text
1855 (in force 1857) · Civil codes
Chilean Civil Code (Andrés Bello)
Chile
A civil code written largely by the jurist Andrés Bello, combining Spanish law, Roman law and the French code.
Built on 2 earlier texts
1865 · Civil codes
Italian Civil Code of 1865
Italy
The first civil code of the new kingdom of Italy, replacing the codes of the older Italian states.
Built on 1 earlier text · Shaped 1 later text
1869 to 1876 · Civil codes
Ottoman Mecelle (Majalla)
Ottoman Empire
The first attempt to put Islamic civil and commercial law, in the Hanafi tradition, into the form of a modern code with numbered articles.
Shaped 2 later texts
1889 · Civil codes
Spanish Civil Code
Spain
Spain's national civil code, written to unify private law while keeping some regional civil laws.
Built on 1 earlier text · Shaped 1 later text
1896 (in force 1900) · Civil codes
German Civil Code (BGB)
Germany
A precise, abstract code built on the German scholarship of Roman law. Its famous 'general part' sets out rules that apply across the whole code.
Built on 1 earlier text · Shaped 11 later texts
1896 to 1898 · Civil codes
Japanese Civil Code
Japan
Japan's modern civil code, adopted in the Meiji period to replace unequal treaties and modernise the state.
Built on 2 earlier texts · Shaped 2 later texts
1907 (in force 1912) · Civil codes
Swiss Civil Code (and Code of Obligations)
Switzerland
A short, clear code in plain language, written by the jurist Eugen Huber, with a separate Code of Obligations.
Built on 1 earlier text · Shaped 3 later texts
Between and after the wars: 1915 to 1989
1917 · Constitutions
Constitution of Mexico
Mexico
A constitution written after the Mexican Revolution, with strong provisions on land, labour and education.
Built on 1 earlier text
1919 · Constitutions
Weimar Constitution
Germany
Germany's first democratic constitution, with a long list of social and economic rights.
Shaped 2 later texts
1920 · Constitutions
Austrian Federal Constitution
Austria
A constitution that created one of the first specialised constitutional courts (Czechoslovakia set one up the same year), designed in Austria by the jurist Hans Kelsen.
Shaped 2 later texts
1925 to 1935 · Civil codes
Thai Civil and Commercial Code
Thailand
A single code covering civil and commercial law, drafted by Thai and foreign jurists.
Built on 4 earlier texts
1926 · Civil codes
Turkish Civil Code
Turkey
Turkey's civil code, adopted as part of the legal reforms of the new republic.
Built on 1 earlier text
1929 to 1931 · Civil codes
Civil Code of the Republic of China
China (now in force in Taiwan)
A civil code adopted by the Republic of China, drafted with the help of foreign models.
Built on 3 earlier texts
1940 (in force 1946) · Civil codes
Greek Civil Code
Greece
Greece's civil code, which replaced Byzantine law that had stayed in force until the 20th century.
Built on 1 earlier text
1942 · Civil codes
Italian Civil Code of 1942
Italy
A civil code that merged civil and commercial law into one text, replacing the code of 1865 and the separate commercial code.
Built on 2 earlier texts · Shaped 2 later texts
1947 · Constitutions
Constitution of Japan
Japan
A post-war constitution that made the Emperor a symbol of the state, guaranteed rights and renounced war in Article 9.
Built on 1 earlier text
1948 · Charters, declarations and treaties
Universal Declaration of Human Rights
United Nations
A declaration adopted by the UN General Assembly, setting out the rights that all human beings are said to share.
Built on 2 earlier texts · Shaped 2 later texts
1948 · Constitutions
Constitution of Italy
Italy
A post-war constitution that created a republic, a long list of rights and a Constitutional Court.
Built on 2 earlier texts · Shaped 1 later text
1948 · Civil codes
Egyptian Civil Code (Sanhuri)
Egypt
A civil code drafted by the jurist Abd El-Razzak El-Sanhuri that combined a French-style structure with rules drawn from Islamic law.
Built on 2 earlier texts · Shaped 3 later texts
1949 · Constitutions
German Basic Law (Grundgesetz)
Germany
Germany's post-war constitution. It begins with the inviolability of human dignity and set up a powerful Federal Constitutional Court.
Built on 2 earlier texts · Shaped 2 later texts
1949 (in force 1950) · Civil codes
Civil Code of the Philippines
Philippines
A civil code that replaced the Spanish code in force since 1889, adding American-influenced rules.
Built on 1 earlier text
1950 (in force 1953) · Charters, declarations and treaties
European Convention on Human Rights
Council of Europe
A treaty protecting civil and political rights, enforced by the European Court of Human Rights in Strasbourg.
Built on 1 earlier text · Shaped 1 later text
1949 (in force 1950) · Constitutions
Constitution of India
India
One of the world's longest constitutions, with a list of fundamental rights, directive principles and a federal structure.
Built on 1 earlier text
1951 · Civil codes
Iraqi Civil Code
Iraq
Iraq's civil code, drafted with the help of Sanhuri, who wrote Egypt's code.
Built on 1 earlier text
1966 · Civil codes
Portuguese Civil Code
Portugal
Portugal's modern civil code, replacing the code of 1867.
Built on 2 earlier texts
1976 · Civil codes
Jordanian Civil Code
Jordan
Jordan's civil code, which draws heavily on Islamic jurisprudence and on the Egyptian code.
Built on 2 earlier texts
1978 · Constitutions
Spanish Constitution
Spain
The constitution of Spain's democracy after Franco, with regional autonomy and a Constitutional Court.
Built on 2 earlier texts
1982 · Charters, declarations and treaties
Canadian Charter of Rights and Freedoms
Canada
A bill of rights built into the Canadian constitution in 1982, with a clause (section 1) that allows reasonable limits on rights.
Built on 2 earlier texts · Shaped 1 later text
1985 · Civil codes
UAE Civil Transactions Law
United Arab Emirates
The federal civil law of the UAE, covering contracts, property and civil liability.
Built on 1 earlier text
The contemporary period: 1990 to today
1991 (in force 1994) · Civil codes
Civil Code of Québec
Quebec (Canada)
A modern civil code for Quebec, the civil-law province of Canada. It replaced the code of 1866.
Built on 1 earlier text
1992 · Civil codes
Dutch New Civil Code
Netherlands
A modern civil code, written over decades, that replaced the code of 1838. It covers property, obligations and contracts in a modern structure.
Built on 2 earlier texts · Shaped 2 later texts
1994 to 2006 · Civil codes
Civil Code of the Russian Federation
Russia
A civil code adopted in several parts after the end of the Soviet Union, setting up a market-economy private law.
Built on 2 earlier texts
1996 · Constitutions
Constitution of South Africa
South Africa
A constitution with a strong bill of rights, written after the end of apartheid, with a Constitutional Court.
Built on 2 earlier texts
1997 · Civil codes
Civil Code of Georgia
Georgia
A civil code written after independence from the Soviet Union.
Built on 1 earlier text
2000 (in force 2001) · Civil codes
Civil Code of Lithuania
Lithuania
A new civil code written after Lithuania regained independence.
Built on 1 earlier text
2002 · Civil codes
Brazilian Civil Code
Brazil
A new civil code that replaced the 1916 code and merged civil and commercial law.
Built on 2 earlier texts
2016 · Civil codes
French contract-law reform
France
A major reform of the contract and obligations sections of the French Civil Code, renumbering articles and modernising its rules after two centuries.
Built on 1 earlier text
What “influenced” means here
We list a link only where the borrowing is widely documented: the drafters used the earlier text as a model. Legal historians sometimes disagree about how much one text shaped another, and many codes combine several sources. The timeline does not list every code, only landmark ones. It is an educational overview, not legal advice.
Cite this page
TheLawToKnow Tools. Legal Codes and Constitutions: Who Copied Whom. https://tools.thelawtoknow.com/legal-codes-timeline.
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