3. The Role of the Japanese Civil Code in the Codification in the Kingdom of Siam

The codification of the Civil and Commercial Code in the Kingdom of Siam was not any case of “legal transplant” in the modern sense, but an active and independent reception of foreign model laws which is comparable to the codification of Civil Code in Japan. Indeed, the Japanese Code played a significant role in the drafting process of the Siamese Code; namely the role as a guideline and navigator for the reception of the German Civil Code. This feature can be clearly recognized especially in the part on the issue “remedies for non-performance of obligations”. Its unique structure coud be quite controvercial. However, just this feature could gain its actual significance in the context of the recent reforms of law on obligations in Germany and Japan.