Two distinct legal systems exist in Canada. In the largely Frenchspeaking
province of Quebec, private law is established by a Civil Code conceptually
similar to that of France and other continental European countries. The other
provinces and territories are common law jurisdictions. While historically the
common law provinces of Canada have tended to attach more importance to British than to American precedent, in recent years American case law has become
increasingly influential with Canadian courts and legislators, particularly with respect
to commercial matters.
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