The scope of this important work, addressing Continental codes for civil law, commercial law and civil procedure, prompts reflection on the supposed absence of such instruments in the law of England and Wales. In European countries commercial law embraces corporate law. The UK Companies Act 2006’s preamble states amongst its principal purposes “to reform company law and restate the greater part of the enactments relating to companies”. The Civil Procedure Rules 1998 pronounce at the outset in rule 1.1(1) that they constitute “a procedural code with the overriding objective of enabling the court to deal with cases justly and at proportionate cost”. So too, the Victorian and Edwardian codifications of three principal nominate contracts, bills of exchange, sale of goods and marine insurance. The Consumer Rights Act 2005 and a handful of other measures encapsulate the bulk of private law regulating consumer transactions. A financial services lawyer would not regard case decisions as a significant source of law in that field. Are we so very different from our European neighbours?

In the Foreword to this encyclopaedic work, written by distinguished comparatist Reinhard Zimmermann, the ambition and provenance of legal codes is identified: “For Max Weber [codification] constituted the culmination, in the field of law, of a specifically European quest for rationality. It is a product of the age of Enlightenment ….” (at v). In the field of private and commercial law, codes govern the activities and transactions of at least half the world, including now the Civil Code of the People’s Republic of China (at 1). The author, Dirk Heirbaut, is a Professor of Legal History at Ghent, and this work is the culmination of decades of research and scholarship, despite the slings and arrows of existence, including serious medical challenges (at vi). Heirbaut cheerfully acknowledges that the lengthy non-appearance of this work became a “running gag” amongst his peers, equated with Samuel Beckett’s Godot. Nevertheless, his labours have been fruitful, as this is destined to be the definitive account of this Enlightenment project which did not fail. Given the location of this review, it will address the relevance of this scholarship for commercial practitioners in common law jurisdictions, who are characteristically suspicious of systematisation and codification. Like teenage children, they tend to prefer things untidy.

The technique employed is one of comparative legal history, combining the methods of those two disciplines, and aiming to rise above a narrowly domestic or national approach. Nevertheless, some anchorage is necessary, and there is a focus on four significantly mercantile European jurisdictions: France, Germany, the Netherlands and Belgium. This corresponds to four national chapters, 2, 3, 4 and 5. Comparative legal history is a hybrid with parents who do not have much in common. Heirbault bemoans that legal historians