Hong Kong is a common law jurisdiction under China’s socialist legal system, which adheres to the civil law tradition. Macao, on the other hand, practices European continental style civil law under the same Chinese legal system. Scotland is a separate civil law entity under the UK’s common law regime. These three places face a common question: how to deal with conflicts arising between their own legal systems and their respective higher legal regimes and how to achieve harmony between the different legal systems.
Unable to display preview. Download preview PDF.