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The term "civil law" as applied to a legal tradition actually originates in
English-speaking countries, where it was used to lump all non-English legal
traditions together and contrast them to the English common law. However,
since continental European traditions are by no means uniform, scholars of
comparative law and economists promoting the legal origins theory usually
subdivide civil law into four distinct groups:
- *French civil law*: in France, the Benelux countries, The Canadian
Province of Quebec, Italy, Spain and former colonies of those countries;
- *German civil law*: in Germany, Austria, Switzerland, Greece,
Portugal, Turkey, Japan, South Korea and the Republic of China;
- *Scandinavian civil law*: in Denmark, Norway and Sweden. Finland and
Iceland inherited the system from their neighbours and colonial masters.
- *Chinese law* is a mixture of civil law and socialist law.
Portugal, Brazil and Italy have evolved from French to German influence, as
their 19th century civil codes were close to the Napoleonic Code and their
20th century civil codes are much closer to the German Bürgerliches
Gesetzbuch. Legal culture and law schools have also come near to the German
system. The other law in these countries is often said to be of a hybrid
nature.
The Dutch law or at least the Dutch civil code cannot be easily placed in
one of the mentioned groups either, and it has itself influenced the modern
private law of other countries. The present Russian civil code is in part a
translation of the Dutch one[*citation needed*].