Class Actions and the “Mixed Law” Regimes that Have Embraced them: A Comparative Reflection on Class Actions in the South African and Quebec Legal Systems
Bibliographic record
Abstract
Abstract: Over the course of the last few decades, class actions have gone from being an essentially American phenomenon to one that is truly international. Class actions have also transcended the common law world and have been adopted by civilian jurisdictions and by “mixed law” jurisdictions such as Quebec and South Africa. In the following article, the authors examine how this unique form of complex litigation has been developed by the courts of South Africa and applied in the context of a recent silicosis case brought against the gold mining industry. The authors proceed to analyze the case — and the issues to which it gives rise — from the standpoint of Quebec law and civil procedure. This analysis shows that while important distinctions exist between Quebec and South Africa, the two mixed law jurisdictions are also quite similar when it comes to class actions and have much to learn from one another.
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How this classification was reachedexpand
Full frame distilled prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. Learned from the 10,348 direct Codex labels and 10,348 direct Gemma labels. Candidate is the union of thresholded teacher heads; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels or direct frontier model labels.
Codex and Gemma teacher scores by category
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.001 | 0.000 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.001 | 0.000 |
| Bibliometrics | 0.000 | 0.000 |
| Science and technology studies | 0.003 | 0.001 |
| Scholarly communication | 0.002 | 0.001 |
| Open science | 0.000 | 0.000 |
| Research integrity | 0.000 | 0.001 |
| Insufficient payload (model declined to judge) | 0.000 | 0.000 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one teacher head, not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".