The Law of Energy Underground 2014
DOI: 10.1093/acprof:oso/9780198703181.003.0005
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Roman-Dutch Law, Custodianship, and the African Subsurface: The South African and Namibian Experiences

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“…148 In some colonial jurisdictions modelled on civil law the connection is clear. Namibia, following the cue of its main colonial influence Germany, has this approach, 149 as do all of the jurisdictions in South America. 150 The South African system is rather conflicted in this respect: South African property law is so strongly modelled on civil law.…”
Section: Cmentioning
confidence: 99%
“…148 In some colonial jurisdictions modelled on civil law the connection is clear. Namibia, following the cue of its main colonial influence Germany, has this approach, 149 as do all of the jurisdictions in South America. 150 The South African system is rather conflicted in this respect: South African property law is so strongly modelled on civil law.…”
Section: Cmentioning
confidence: 99%