Specisics of Judicial Precedent in Common Law and Civil Law Systems (Comparative Analysis).

Abstract

In the article specifics of judicial precedent in common law and civil law systems has been researched. On the basis of associated stare decisis and jurisprudence constante doctrines comparative analysis of English and continental models of judicial precedent has been made.

Keywords

• judicial precedent
• stare decisis
• jurisprudence constante
• ratio decidendi
• obiter dictum