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Thanks for that, Martin. I shall try to look up the reason, but my first thought is that it is historic, possibly from the Institutions of Justinian who gave us the Codex in Roman times. Most of the world is in fact ruled by one or other legal system due to France and UK having colonised a lot of the known world in the 17-19th centuries. So Canada, Australia, NZ and parts of RSA inter alios have adopted our system. But, Quebec, Louisiana, and many countries have taken to the Civil code, they dropped the name Napoleonic when he made his way to St Helena. Other nascent countries such as Mexico and Japan many S American states have also adopted the Civil code, but as the French only settled RSA, and the Dutch and British colonised it, only Dutch and our legal systems apply.

I have said all this off the top of my head (and while listening to Yesterday in Parliament) so if anyone knows of any innocent misrepresentations please correct me.

And, Ian, may I just mention that the Wills Act, 1837, was an Act of Parliament which is supposed to be sovereign, although there is a lot of talk to the contrary on the airwaves at present. What I find ironic is that A P Herbert MP (Liberal) was the promoter of the first Family Provision Act in 1938. Doesn't sound very liberal to me, but who am I to comment...