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Open Access Publications from the University of California

How Global is the Common Law? A Comparative Study of Asian Common Law Systems – Hong Kong, Malaysia, and Singapore

  • Author(s): NG, Kwai Hang
  • JACOBSON, Brynna
  • et al.

AbstractThis article compares three common law jurisdictions in Asia – Hong Kong, Malaysia, and Singapore. By studying the use of foreign citations in the reported opinions of these jurisdictions, we show that they have acquired a judicial character that is distinctively outward-looking and global. The variety and range of foreign citations suggest that the phenomenon cannot be fully explained as a matter of colonial legacy. The article further discusses the ways in which the use of foreign case citations serve as a means for legal and professional enrichment.

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