Iran was never colonised, but like most other Asian and African nations it fell under considerable influence and control by economically and military stronger Western nations, especially Great Britain and Russia. Because it was never formally incorporated into a wider colonial empire, its legal system developed by deliberately borrowing from various legal systems deemed to have been more successful than its own traditional system.

This presentation thus seeks to investigate the active engagement of a non-Western society during 19th and early 20th century with a legal tradition they identified as simultaneously more powerful and sharply at odds with its own. It seeks to develop commonalities and differences in the colonial encounter through a comparison of the Iranian experience with other Muslim experiences, but in particular with the very different Japanese approach. Individuals in all three of these cultural spheres sought to capture what made the West so powerful and transpose that essence at home. They all identified the Western legal tradition as a particularly important component of modernity and an enduring source of strength.