Federalism and Legal Unifi cation: A Comparative Empirical Investigation of Twenty Systems

How and to what degree do federations produce uniform law within their system? This
comparative empirical study addresses this question comprehensively for the first time, by
examining legal unification in twenty federal systems around the world.
An earlier version of the General Report was presented at the Thematic Congress of the
International Academy of Comparative Law on The Impact of Uniform Law in National Law:
Possibilities and Limits, Mexico City, November 13-15, 2008. The General Report presents the
means and methods of legal unification, the degree of legal unification of each system (and of
particular areas of the law within each system), and a first attempt to explain the driving forces
of legal unity and diversity in federations more generally.
Each federation is presented in a National Report structured along the lines of a questionnaire
that was distributed to the reporters (and is included in Appendix 3 of the General Report).
While some reporters hewed close to the questionnaire, others took up the invitation to provide
a broader analysis of legal unification in their federation.
We are grateful for the efforts and talent of Professors Halberstam and Reimann in conducting
this inquiry, and thereby enhancing the Mexico City Congress and, more importantly, our
understanding of a crucial comparative law enterprise. We also join them in thanking the
National Reporters for their indispensable contributions to the project, as well as the additional
experts – too numerous to mention here – for taking the time to provide the underlying data.
New York and Mexico City, February 1st, 2012
George A. Bermann, President of the International Academy of Comparative Law.
Jorge A. Sánchez Cordero, Director of the Mexican Center of Uniform Law.