One of the country’s most distinguished & sought after M&A and competition lawyers, in an exclusive interview with Legal Era Magazine
LE: Prior to joining P&A Law Offices, you practiced law in Brussels, Cleveland, and Palo Alto. What are the key differences between their legal systems and ours?
The EU, the US, and India all have unique legal systems that have evolved over time. The EU’s system is a legal regime at the EU-wide level, operating together with the laws of each of the Member States. There are EU laws and regulations that have direct applicability and create rights and obligations at an EU-wide level for the residents of all of the Member States. Then there are the laws of each of the Member States, a majority of which are influenced by the Napoleonic Code, and are applicable to the residents of that Member State, who in specific areas implement EU laws as a result of EU directives. The US and India have common law systems.
In the US, there is a distinction to be made between federal law matters and state law matters. And the laws of some of the States in the US can differ significantly from State to State. Likewise, in the EU, the laws of the Member States can differ from State to State quite significantly in some areas.
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