aid, is the product of Roman and customary law, together with
the ordinances of the kings and the laws of the Revolution. In form it
has passed through several changes caused by the political vicissitudes
of the country, and it has of course suffered from time to time
important alterations in substance, but it still remains virtually the
same in principle as it left the hands of its framers. The code has
produced a vast number of commentaries, among which may be named those
of A. Duranton, R. T. Troplong and J. C. F. Demolombe. The remaining
French codes are the _Code de procedure civile_, the _Code de commerce_,
the _Code d'instruction criminelle_ and the _Code penal_. The merits of
the French code have entered into the discussion on the general question
of codification. Austin agrees with Savigny in condemning the ignorance
and haste with which it was compiled. "It contains," says Austin, "no
definitions of technical terms (even the most leading), no exposition of
the _rationale_ of distinctions (even the most leading), no exposition
of the broad principles and rules to which the narrower provisions
expressed in the code are subordinate; hence its fallacious brevity."
Codes modelled on the French code have, however, taken firm root in most
of the countries of continental Europe and in other parts of the world
as well, such as Latin America and several of the British colonies.

The Prussian code (_Code Frederic_) was published by Frederick the Great
in 1751. It was intended to take the place of "Roman, common Saxon and
other foreign subsidiary laws and statutes," the provincial laws
remaining in force as before. One of the objects of the king was to
destroy the power of the advocates, whom he hoped to render useless.
This, with other systems of law existing in Germany, has been replaced
by the Civil Code of 1900 (see GERMANY).

The object of all these codes has been to frame a common system to take
the place of several systems of law, rather than to restate in an exact
and exhaustive form the whole laws of a nation, which is the problem of
English codification. The French and Prussian codes, although they have
been of great service in simplifying the law, have failed to prevent
outside themselves that accumulation of judiciary and statute law which
in England has been the chief motive for codification. A more exact
parallel to the English problem may be found in the _Code of the State
of New York_. The revised constitu