Roman law in the form of the legislationof the emperor Justinian has been studied in Western Europe since the end of the eleventh century in Bologna.1

It has had enormous authority - mostly on an informal basis, but bolstered by a strong ideology.² Since 1900, the year in which the German civil code came into force, hardly anywhere in Europe has it been possible to speak of Roman law as a direct source of current private law.³ Nevertheless, it was — and still is — a ‘common frame of reference’ long before this expression was coined in the frame­work of European private law of the future.⁴

1.