“Daqing minlu cao'an” fayuan bianxi.

The Great Qing Draft Civil Code, the first Chinese code of civil law, has been a topic of historical debate. Some historians believe that it was largely based on German law, while others see Japanese law as the original model. The article argues that the Japanese Meiji Constitution was the blueprint for the Qing Draft Civil Code, based on the following points: 1) After the Meiji Restoration took place, Japan’s economy improved significantly and many Qing scholars studied in Japan; 2) Japanese experts were invited to China during the drafting of the law; 3) The most frequently printed foreign legal document during the Qing dynasty was the Japanese Civil Code; 4) While the Qing Draft Civil Code had some stylistic similarities with German laws, this was due to Japan’s integration of some aspects of German Law at the end of the 19th century; and 5) Many Chinese legal terms can be traced to the Japanese language.