for public law including criminal prosecution. As a result, modern-day Quebec is now one of only a handful of bijuridical jurisdictions in the world where two legal systems co-exist. The Quebec Act was opposed by the English minority who believed that British citizens should be governed by English law. The Constitutional Act of 1791 resolved the dispute through the creation of Upper Canada west of the Ottawa River (subject to English common law) and Lower Canada around the St. Lawrence River (where civil law was maintained). The need for codification The practice of civil law in Lower Canada became quite complex by the middle of the 19th century, because of the multiple sources of law that needed to be drawn upon most only available in French. As identified by René-Édouard Caron, the "law of the land" included: the Custom of Paris as it was in 1663 during 16631759, edicts and ordinances of the French Crown that applied to Canada during 16631759, ordinances of the Conseil supérieur laws, edicts and ordinances issued by the French Crown for France that were registered with the Conseil supérieur statutes of the British Parliament passed since the Conquest for Canada, or which specifically named Canada during 17591764, laws passed by the British military government prior to the Treaty of Paris during 17641791, laws passed by the Legislative Council of Quebec Provincial Statutes of Lower Canada, 17911840 Ordinances of the Special Council of Lower Canada, 18381841 from 1840, Acts passed by the Parliament of the Province of Canada applicable to Lower Canada English criminal laws as they existed at the passage of the Quebec Act 1774 as amended for matters not treated in the above categories: pre-revolutionary French legal writers, such as Robert Joseph Pothier, Jean Domat, and Angers Canadian legal writers, such as Doucet, Crémazie, Louis-Hippolyte LaFontaine, and Bonner case law incorporating French case law and judgments published in Canadian law reports English public law applicable throughout the British Empire affecting the rights of British subjects In 1859, Désiré Girouard (later a judge of the Supreme Court of Canada) noted: Creation In 1857, the Legislative Assembly of the Province of Canada passed An Act respecting the Codification of the Laws of Lower Canada relative to Civil matters and Procedure, to authorize the codification of the civil law then currently in force in Lower Canada. The Act's preamble declared: The Act authorized the creation of a