At first glance, the largest country in southeast Europe seems like a curious place for a skirmish between the continental and Anglo-Saxon legal systems. Romania has been a civil law country since at least 1864, when it translated large swathes of the Napoleonic Code and adopted them as its own.

But its long journey towards membership of the European Union (EU) has provided Romania with a unique opportunity to adapt its venerable civil law instruments to meet the economic and social challenges of a new century. In doing so, Romanian legislators have frequently looked to the common law for inspiration.