As the clash between the EU and the UK on how to achieve an invisible north-south border on the island of Ireland reminds us, the EU and the UK have very different mindsets — not least about their respective systems of law. As the French management saying goes: “That works all very well in practice, but it will never work in theory.” […] It was Karl Friedrich von Moser, the German jurist, state journalist and politician, who wrote in 1758 that “each nation has its main characteristic. In Germany it is obedience, in England it is liberty, in France, the honour of the King”. […] There are good reasons for the UK, now that it has left the EU, to lift off the blanket of inherited EU legal code. […] What now lies ahead is the opportunity to re-establish the UK’s system of law, so that it fits more comfortably with UK society and our decentralised modes of reasoning.
Click here to read the full article