legal systems may also be presented therefore, as points of reconciliation In our day all legal systems are mixing in one way or another. Legislatures and courts are looking at other jurisdictions at least for inspiration if not for direct borrowing, in an effort to improve responses to shared human problems. Legal ideasand institutions are crossing borders rapidly. Although this is applicable to all legal systems today, the result of this mixing is not necessarily the creation of a mixed system'.. Then there are new mixes. These are'systems in transition,shifting systems'.The lew forms in these systems challenge the esta blished conceptual and analytical frameworks of comparative law in such aspects as classif ication of legal families, the role and value of receptions theories of convergence and divergence, the dynamism of comparative law, and the concept of the legal system itself. 9 3. Public law in mixed legal systems Is there a specific character to public law in mixed legal systems? As observed earlier, some mixed legal systems such as that of Scotland, are parts of unitary States, some, such as that of Louisiana, are within Federal States. A number of others, such as those of South Africa and Algeria, are independent States. Historically mixed jurisdictions, especially those that were part of a bigger whole, showed this mixed character in the area of private law alone In some of today's mixing systems such as those in Eastern and Central Europe, public law is acquiring a mixed character. In restructuring the State, foreign models are being used here For example, in the area of constitutional law, a selective mixture of some institutions from the American and German models, as well as the French and american models may win the day. another area where this occurs today is criminal law, regarded as part of public law where elements of inquisitorial and accusatorial systems are being reconciled and adopted such as in Albania. So, mixes are taking place in areas other than private law in the new 4. Public law as a 'mixed system We are looking more often now at fields of law that are acquiring a mixite', and public law surely is one of these fields. Much of the future of comparative legal studies will be dealing with public law and especially with public law as a 'mixed system'. In the area of public law, there is a vast amount of transmigration of ideas and reciprocal influence, for example between the USA and Europe, within Europe and between the USA, Europe and South east Asia. So the end result will be the birth of a mixed system as to public law Should comparative legal studies now consider only 'mixite'andmixes'of legal systems and areas of law? Especially within the context of the European Union, both current and future developments in law, whether understood as rules as lawor"law in context,are predominantly approached within the convergence debate. Could we therefore talk of law as transposition? The European Community concept ' freedom of movement of.. can be regarded as extend ing to the freedom of movement of laws and legal institutions. The results of this freedom of movement can be ' mixes, but not all"mixes' produce such major change, change which would qualify an area of law to be called mixed. In the first place, mixes as to content and mixes as to structure produce different outcomes second ly how much of a mixlegal systems may also be presented therefore, as points of reconciliation. In our day all legal systems are mixing in one way or another. Legislatures and courts are looking at other jurisdictions at least for inspiration if not for direct borrowing, in an effort to improve responses to shared human problems. Legal ideas and institutions are crossing borders rapidly. Although this is applicable to all legal systems today, the result of this mixing is not necessarily the creation of a ‘mixed system’. . . . Then there are new mixes. These are ‘systems in transition’, ‘shifting systems’ . . . The new forms in these systems challenge the established conceptual and analytical frameworks of comparative law in such aspects as classification of legal families, the role and value of receptions, theories of convergence and divergence, the dynamism of comparative law, and the concept of the legal system itself.9 3. Public law in mixed legal systems Is there a specific character to public law in mixed legal systems? As observed earlier, some mixed legal systems such as that of Scotland, are parts of unitary States, some, such as that of Louisiana, are within Federal States. A number of others, such as those of South Africa and Algeria, are independent States. Historically mixed jurisdictions, especially those that were part of a bigger whole, showed this mixed character in the area of private law alone. In some of today’s mixing systems such as those in Eastern and Central Europe, public law is acquiring a mixed character. In restructuring the State, foreign models are being used here. For example, in the area of constitutional law, a selective mixture of some institutions from the American and German models, as well as the French and American models may win the day. Another area where this occurs today is criminal law, regarded as part of public law, where elements of inquisitorial and accusatorial systems are being reconciled and adopted, such as in Albania. So, mixes are taking place in areas other than private law in the new mixing systems. 4. Public law as a ‘mixed system’ We are looking more often now at fields of law that are acquiring a ‘mixité’, and public law surely is one of these fields. Much of the future of comparative legal studies will be dealing with public law and especially with public law as a ‘mixed system’. In the area of public law, there is a vast amount of transmigration of ideas and reciprocal influence, for example between the USA and Europe, within Europe and between the USA, Europe and South East Asia. So the end result will be the birth of a mixed system as to public law. Should comparative legal studies now consider only ‘mixité’ and ‘mixes’ of legal systems and areas of law? Especially within the context of the European Union, both current and future developments in law, whether understood as ‘rules as law’ or ‘law in context’, are predominantly approached within the ‘convergence’ debate. Could we therefore talk of ‘law as transposition’? The European Community concept ‘freedom of movement of . . .’ can be regarded as extending to the freedom of movement of laws and legal institutions. The results of this freedom of movement can be ‘mixes’, but not all ‘mixes’ produce such major change, change which would qualify an area of law to be called ‘mixed’. In the first place, mixes as to content and mixes as to structure produce different outcomes. Secondly, how much of a mix 9 Ibid., 351