It is not surprising that at that time, European comparative law researchers first turned to Canada to conduct their studies. [24] Observation of the Canadian literature has allowed researchers to understand that the crucial aspect of multilingual legislation is the national interpretation and application of the multilingual normative declaration. [25] The fruitful interaction between Canadian and European research quickly highlighted structural differences between Canada`s consolidated multilingual experience and the European Union as the main initial global effort to create unified remedies to express a single legal system. One particular aspect seems almost obvious: unlike Canada, the EU is not a state, but an international organisation that has specific tasks, especially the completion of the internal market. Therefore, the legislative intent of the EU standard is not primarily in a message to a social group, but in the aim of harmonising each individual European directive or regulation. In addition, in Canada, translators of both official versions – French and English – can often draw on concepts rooted in an already existing legal tradition. This occurs particularly in the translation of state law, but federal legislation also often deals with areas of law that are not unknown to lawyers of the Western legal tradition,[26] although in the diversity of legal and linguistic cultures of civil law and common law systems. Most general legal studies have some similarities, but there are also differences. The normative perspective of an internal actor is generally lacking in general studies, but the mutual dissimilarity of general studies makes it possible to avoid too close a similarity. Several newcomers to the field of general studies, such as law and economics, can be beneficial to both comparative law and the study of teaching.6 From the point of view of comparative law, one of the most interesting new areas is the linguistics of comparative law, which, in the family of law, is very close to comparative law.7 It is often very difficult to 8 The similarity between comparative legal linguistics and comparative legal linguistics Law is easy to understand because legal texts exist in different systems in different languages. On the other hand, it must be remembered that problems of legal language are not only caused by non-national factors, but can also be internal: legal doctrine also works with legal language and is epistemically related to it. The historical method can therefore, as can be seen in this example, reveal other similarities and/or differences at a deeper level compared to what emerges from a surface-level analysis.24xFor a historical analysis of cultural differences that explains the different approaches to commercial law in England and France, see Foster 2007, in particular at pp.
269-277. The central place of language in comparative law research has long been recognized in the scientific community, and the study of legal translation in its various forms is now an established field of research. However, the only seemingly stable relationship between comparative law and language – in which the methodology of comparative law is applied to legal translation as a subject of analysis – is irrepressible in nature, as it accompanies current changes in the legal world. This is particularly evident in the multilingual contexts of the EU, where comparative law ensures a correct reading of the complex link between the EU legislator and national courts. As we will see in this article, the respect and qualification of EU law by the methodology of comparative law – in combination with other methods such as semiotics – shows that a consolidated EU legal language is emerging, resulting from a synergy between EU legal concepts and the results of interpretations by national courts. Here, comparative law goes so far that it becomes the catalyst for an already existing phenomenon, a consolidation of the legal language of the European Union, which would not be visible without adequate methodological support and would risk dissipating its own possibilities.
