Abstrakt
The author compares the principles of the legal culture of Europe and the Far East in a historical context. The paper considers legal transplants and their launching into legal systems of countries in the Far East, namely China, Japan, Korea and Vietnam since 1868.
The author follows the impact of individual foreign legal systems stemming from Continental Law (the German subsystem and the Roman subsystem) and Common Law. The impact of German law prevailed in the Far East countries listed above, but the influence of US law primarily in modern Japan should not be underestimated.
The paper deals with the transposition of foreign patterns into the respective written law, i.e., law in books. In addition, it demonstrates through concrete examples how inter-pretation of the law in books developed, i.e., law in action, which quite often shifted the original European meaning closer to traditional East-Asian mode of thinking