18. BRYCE: THE EXTENSION OF LAW 593 plain that it is too Teutonic ; others that it is not Teutonic enough. One may perhaps conclude from these opposite criticisms that the codifiers have made a judiciously impar- tial use of both Germanic and Roman materials. Speaking broadly, it may be said that the groundwork of both the French and the German Codes — that is to say their main lines and their fundamental legal conceptions — is Roman. Just as the character and genius of a language are determined by its grammar, irrespective of the number of foreign words it may have picked up, so Roman law re- mains Roman despite the accretion of the new elements which the needs of modern civilization have required it to accept. The fifth stage is the transplantation of Roman law in its modern forms to new countries. The Spaniards and Portu- guese, the French, the Dutch, and the Germans have carried their respective systems of law with them into the territories they have conquered and the colonies they have founded; and the law has often remained unchanged even when the territory or the colony has passed to new rulers. For law is a tenacious plant, even harder to extirpate than is language; and new rulers have generally had the sense to perceive that they had less to gain by substituting their own law for that which they found than they had to lose by irritating their new subjects. Thus, Roman-French law survives in Quebec (except in commercial matters) and in Louisiana, Roman- Dutch law in Guiana and South Africa. The cases of Poland, Russia and the Scandinavian king- doms are due to a process different from any of those hith- erto described. The law of Russia was originally Slavonic custom, influenced to some extent by the law of the Eastern Roman Empire, whence Russia took her Christianity and her earliest literary impulse. In its present shape, while re- taining in many points a genuinely Slavonic character, and of course far less distinctly Roman than is the law of France, it has drawn so much, especially as regards the principles of property rights and contracts, from the Code Napoleon and to a less degree from Germany, that it may be described as being Roman " at the second remove," and reckoned as an outlying and half-assimilated province, so to speak, of
