The Influence of Legal English on Legal French in a Globalized World - An outline from the perspective of legislation in France and Québec

This master's thesis explores the dynamics of contact between two dominant Western legal cultures - Civil Law and Common Law - in the context of globalization. It analyses the legislative and terminological strategies employed by Francophone lawmakers in France and in Quebec in response to the need to implement legal institutions ofAnglo-American origin. The thesis focuses on the tension between the pressure to modernize legal systems driven by international trade and the effort to preserve the conceptual autonomy and linguistic integrity of domestic law. Its aim is not to assess the desirability of legal transplants as such, but to analyse their conceptual and linguistic articulation within the receiving legal orders. Methodologically, the thesis adopts an interdisciplinary approach combining tools from comparative law, comparative legal linguistics, and legal translation theory. In the theoretical part, the author outlines the fundamental differences between the Civil Law tradition, based on codification and deductive reasoning, and the inductive and case-based nature of Common Law, which provides the necessary interpretive framework for understanding the difficulties associated with the transposition of foreign institutions. Special attention is paid to Quebec as a mixed legal system, whose...