Comparative law may not sound international at all, but it is significantly more so than private international law (PIL) might suggest. As the name implies, comparative law compares regulations from legal systems worldwide, highlighting their commonalities or differences. A few peculiar differences will be discussed further below.
Globally, there are notably the Romanistic, German, Anglo-American, and Nordic legal systems, as well as law in the Far East and religious laws (1). The Romanistic legal system includes, for example, Italy, Spain, and France; the German system includes Germany, Austria, and Switzerland; the Anglo-American system includes England and the USA; and the Nordic system includes the Scandinavian countries. China and Japan are primarily assigned to the law in the Far East, and Islamic and Hindu law to religious laws.
In comparative law, a distinction is made between macro- and micro-comparison:
– Macro-comparison does not examine individual problems, but rather the general methods of dealing with law, for example, how disputes are settled or how jurisdictional questions are divided between courts and lawyers.
– Micro-comparison, however, deals with the comparison of individual legal institutions or problems, for example, under what challenges is the manufacturer of a product liable for damage suffered by the consumer due to a defective condition? Or what rules govern claims processing in road traffic accidents?
Now, back to the initial question: a limping marriage is a marriage that is recognized as legally valid in one country but considered invalid in another. This can lead to various family law problems.
And finally, what about a proxy marriage? These exist in other countries, particularly within the Romanistic legal system, but not in Germany, because in Germany, marriage is a highly personal right. In other countries, one can be represented before the registrar when marrying, and prefer to drink a beer or lie on the beach oneself.
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