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The reasons are historical. In the mid-seventeenth century, Dutch settlers began to occupy the part of South Africa now known as the Western Cape. South African law reflects this history of successive colonial governance. The ‘common law’ of the country in this context, ‘common law’ implies law of non-statutory origin is based on the ‘Roman-Dutch’ law of the original Dutch settlers. This is civilian law – Roman law as interpreted by the Dutch writers of the 17th and 18th centuries.
Thus originally, important primary sources of South African law were the treatises of authors such as Grotius, Johannes Voet, Simon Groenewegen and Johannes van der Linden. Law was modified or expanded by statute. When the British took possession of the Cape in they did not impose their substantive legal system in a formal way. Instead, it was decided that the local Roman-Dutch law would remain in force. However, English procedural law was adopted and this had a tendency to influence substantive provisions.
Furthermore, Roman-Dutch Law did not always cater for the requirements of the modern society that developed during the 19th century, necessitating legislative innovation, which was often based on English acts and interpreted using relevant English precedent. The advocates and judges of the superior courts were usually trained in England and tended to rely on their English treatises. As a result of such factors, the Roman-Dutch law of the Cape Colony was overlaid with a heavy English law influence.
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