Judicial precedents between “binding” and “persuasive power"

comparative notes and reflections about the new Brazilian Code of Civil Procedure and its “súmula vinculante”

Abstract

In this text the writer makes a comparison between innumerous countries about the authority of judicial precedents. Between those countries, there are also those of common law. His conclusions are that, even if there are many common points, the way of thinking of a jurist of civil law will always be different of a jurist from the common law.