This thread is making me wonder to what extent other countries have such a wide disparity in substantive law between sub-national jurisdictions.
For example, are there things that you can legally possess in Bavaria (not just tolerated, but actually legal) but that would get you arrested if you were caught with them in Berlin?
The question doesn’t just cover firearm or criminal law.
How many countries are Federal in nature? Or have a quasi-Federal nature. Figure that out and you know. In the UK,l England and Wales, Scotland and Northern Ireland each have their own legal system. The various Australian states. The provinces of others.
Unitary States are the exception these days not the rule. Outside of Europe and Africa. Even within unitary states, the sub divisions may have substantial delegated powers to make law as they see fit.
Switzerland’s cantons can have widely varying laws, down to different official languages. One canton held out on giving women the vote until 19 years after they got it at the federal level, and 31 years after the first canton did.
that was 1990, BTW :eek:
That is why I come here. Never would have known that.
In Canada, the criminal law is federal and uniform across the country, so there is no variation in the firemarms laws example given in the OP.
However, in other areas, the provinces have sole jurisdiction and there can be considerable variation. The clearest example is that in Quebec, the civil law is based on French/Roman civil law, while in the other provinces and territories, the civil law is based on English common law.
Another example is language - there is considerable variation in official languages. New Brunswick is the only officially bilingual province. Quebec’s official language is French, but it is constitutionally required to provide certain services in both languages. Manitoba’s official language is English, but it is constitutionally required to provide certain services in both languages. Other provinces, such as Ontario and Saskatchewan, are not under any constitutional obligation to provide any services in both languages, but do so to varying degrees.
If you consider the UK and its Overseas Territories then you get some huge differences between the colonies and the mother country.
Example:
There is a criminal offense of “Insulting the Modesty of a Woman” in the Cayman Islands. You could be fined and/or imprisoned up to three years for stating that an unmarried woman is not chaste, though it is more commonly added as a pile-on charge for indecent exposure cases (which is a separate offense in its own right) or used in dealing with other somewhat pervy behaviour that otherwise would be dealt with by another law. However, there is no offense of Insulting the Modesty of a Man.
As best I can tell such an offense does not exist under English law.
similarly, in Canada the western provinces recognised women’s franchise during WWI; the federal government in 1921; Qu3ebec did not do so until 1940.
While prosititution is legal in all of Germany, in Bavaria it is illegal (for both parties) to have unprotected (oral) sex. This is not the case in the rest of Germany and unprotected oral sex is pretty common in a lot of places.
I assume you mean in the context of a prostitute-client situation, not a private one?
Yes, off course… otherwise we’d soon be out of Bavarians.
The United Arab Emirates are really, really independent from each other.
This is about a stricter health code in Bavaria. It’s not a criminal law, neither a prostitute nor her customer goes to jail if they don’t use a condom for oral sex. The brothel will be fined by the local health authority, though (if they find out about it).
Compared to the situation in the United States or the United Kingdom, laws in Germany are pretty much uniform all over the country. The criminal code in Germany is a Federal law and thus exactly the same everywhere.
The laws are, however, not enforced in the same manner in all places. For instance, you might get away with a suspended sentence for committing a crime in one of the Northern states whereas you will be sent straight to prison by a judge in Bavaria.
Quite frankly, I fully expect that both Hong Kong and Macau will eventually be integrated.
According to Wikipedia, age of consent may differ in various locations (bolding mine):
There’s a Bavarian Cream joke in there somewhere.
Spain has several different civil and taxation systems, but the general criminal code is country-wide.
Well, if you view the United Kingdom as the country in the OP, then England & Wales have a completely separate legal (and school) system to that in Scotland - not just terminology but basic legal tenants.
The most well known differences being in jury verdicts (Scotland having the extra one of “not proven” commonly referred to as “don’t do it again!”) in criminal law and the lack the concept of freehold as opposed to leasehold in property law.
Yes, Scotland has a separate legal system and the Scottish Parliament has substanstial powers but a significant number of key areas are retained by the UK Parliament in Westminster. These areas include firearms and drug law.
I didn’t know that’s how Bavarians are made.