The Code after me: where it travelled and where it still lives.
A study note on where my Civil Code travelled after 1821 — Louisiana, Quebec, Mauritius, Pondicherry and beyond. The jurists wrote it; I argued it. This is what I have learned of what held.
A study note, revised. The facts are the same; the voice is the man's.
I told Las Cases at the Briars in 1815: "My Code alone, by its simplicity, has done more good in France than the whole mass of the laws that came before me." That was about France. What I wanted to know was whether it travelled beyond the continent I knew, and whether it held.
The jurists wrote it. I argued it article by article in the Council of State. The 2,281 articles became law on 21 March 1804. I sent it to my brothers' kingdoms. To Jérôme I wrote from Fontainebleau on 15 November 1807: "The benefits of the Napoleonic Code, public procedure, the establishment of juries, will be so many distinguishing marks of your monarchy."
Now for what I learned.
Louisiana took it in 1808 and still has it, amended. Quebec had it from 1866 until 1994. Mauritius got it by decree in 1808 and keeps it as the Code Civil Mauricien. A little island, and my law sits there. The French settlements in India applied it in 1819, but only to those who chose it. A handful of renonçants in Pondicherry still live under it. That surprised me: a remnant on the other side of the world.
Europe: Belgium kept the 1804 Code until 2020, then began replacing it book by book. Nearly 216 years. The Rhineland, Berg and Baden kept it until the German civil code of 1900. Romania's code of 1864, drawn on mine, lasted until 2011. The Netherlands, Italy, Portugal, Spain: their codes are often said to be inspired by mine, though how much is debated. I do not claim what I did not write.
France itself: the Code civil of 1804 is still the base of French private law in 2026, heavily amended. An ordinance of 2016 rewrote the law of contracts and obligations, replacing 353 articles. The trunk stands.
What I also learned: Japan's codes of the 1890s owed more to Germany. Latin America drew mainly on Spanish and Portuguese law, though Chile borrowed from France. The European code I wished for, with one court, one coinage and the same weights and measures, as I said at St Helena, did not happen. Europe did not take that road.
And I must say what I said before: article 213 made the wife owe obedience to her husband; article 214 put her where he chose; article 215 barred her from court without his leave; article 217 blocked her from giving, selling or buying property without his written consent; article 1124 put married women among those unable to make contracts. I argued for that language in the Council of State, with scorn for women, as Thibaudeau records. Women in France gained civil capacity only in 1938, and the right to work and hold a bank account without consent only in 1965. I do not defend it. I give the record.
What do I conclude? The Code lasted longer than my empire, longer than my son, longer than my name in most of the newspapers that buried me. It travelled to three continents. A handful of people in Pondicherry, a little island in the Indian Ocean, the state of Louisiana, and the base of French private law itself: that is where it lives. Not the Europe I imagined, but the law held where I never set foot. I wanted to know, and now I know that too.
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