The Civil Code of Quebec was enacted in 1866. It codified the then existing law which was largely of French origin. The Code was modelled on the French Civil Code but to the three books into which that Code was divided was added a fourth book dealing with commercial law. In this respect, therefore, the French tradition of a separate commercial code was not followed. The codification was regarded as an affirmation of French legal culture in the face of the growing threat of a penetration by English law. Nevertheless, both in the codification stage and in the subsequent evolution of the law, concessions were made to the English legal system. For instance, the trust was introduced into the Civil Code. Again, the fact that final appeals from decisions of the Quebec courts could be brought before courts which were dominated by English-trained judges contributed to the penetration of English legal concepts.1 For instance, these courts applied English ways of interpreting statutes to the construction of Code provisions. On the whole, Quebec courts tried to resist these tendencies and to preserve as far as possible the French character of the legal system. They were hampered, however, in these efforts because they were compelled to accept the English view that decisions of the superior courts constituted binding precedents.