frameworks are a melting pot of historical influence, partly indigenous and partly imported through colonial histories.

Different legal systems have comparative strengths and weaknesses when it comes to gender rights (see Annex 3 for a complete list of countries by legal tradition). Historically family law was traditionally seen as non-state law that was determined by traditional authorities such as tribal chiefs and religious officials. Over time and at different times, states started assuming control over family law as part of a state-building process either through sidelining the traditional authorities or striking bargains to consolidate their power.<sup>13</sup> Socialist systems were the most progressive on paper when it comes to gender rights and these legal traditions typically do not have legal constraints. The socialist revolution in the Soviet Union in 1917 deliberately diminished the role of the church by liberalizing divorce laws and requiring that all marriages be civilly registered. A 2003 study highlights that the earliest reforms of family law did not take place in the most developed economies and the most democratic political regimes. Some countries were very early reformers – most of the reforms in the Nordic countries took place during the early 1900s. By 1930, the laws regarding divorce and matrimonial property were gender equalized. The explanation offered for this is a higher degree of securalization and the presence of two dominant ideological movements. The combination of liberal left ideologies with secularist ideas was the backbone of this reform.<sup>14</sup> Civil law systems historically deriving from Roman law are found for example in Latin America, Francophone and Lusophone ex-colonies in Africa, the Middle East and North Africa, East Asia Pacific and the former colonizing countries in Europe such as France, Spain, Portugal, Germany and the Netherlands. Roman law shaped the 1804 Napoleonic Code that was adopted in Latin America and continental Europe. The 1900 German Civil Code was heavily influenced by the Napoleonic Code but was differently structured and influenced the family codes in Korea and China.<sup>15</sup> Both codes were advantageous when it came to division of marital property<sup>16</sup> and inheritance rights but they also tended to bestow greater control to the husband over assets and the wife’s actions than common law systems. The need for marital authorization still existed in some countries in Europe until the latter part of the twentieth century. The head of household provision was reformed in France in 1974 and the husband’s control over marital property was removed finally in 1985. The need for spousal permission to work remained on the books up to 1978 in Spain and 1984 in Switzerland. Significant reforms to the wife’s control over her personal property took place in the early 20<sup>th</sup> century in some countries in Latin America. Reforms to the husband’s sole administrative control over joint marital property and over family affairs took longer to achieve in many countries; many of these later changes that took place are captured in the database.

> 13 Htun and Weldon 2011.

> 14 Antokolskaia 2003.

> 15 Htun and Weldon  2011.

> 16 It should be noted that divorce was not permitted in many Catholic countries in Europe and Latin America until the mid to late 20<sup>th</sup> century.

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