Scandinavia

By Hester Swift, Foreign and International Law Librarian, June 2009. Updated June 2011.

Introduction

This research guide defines Scandinavia as consisting of Norway, Sweden, Finland, Denmark and Iceland, since the five countries have close cultural, historical and administrative links. Scandinavia has a somewhat complicated political history, with Denmark and Sweden dominating for many centuries. Norway in its modern form gained independence in 1905 (it had previously been independent in the Middle Ages, until 1380). Finland declared independence in 1917 and  Iceland attained full independence in 1944.  Denmark, Sweden and Norway are constitutional monarchies, while Iceland and Finland are republics. Finland has two official languages: Finnish and Swedish.

The Scandinavian (or Nordic) legal systems can be classed as a branch of the civil law family, although some scholars put them in a separate category, alongside civil law, common law and other types of legal system. Roman law has had less influence in Scandinavia than in Continental Europe and the Scandinavian states do not have systematic codes comparable to those of countries like France and Germany.

There has been a tradition of legislative unification, or cooperation, in Scandinavia since the latter part of the nineteenth century. Norway, Denmark and Sweden began the process and Finland became involved later; Iceland has participated to a lesser extent in the drafting of uniform laws, but has often enacted the laws agreed on by the other four states. The work continues under the aegis of the Nordic Council, which was established in 1952.

Denmark, Finland and Sweden are members of the European Union. Although Norway and Iceland are not, they apply a large proportion of EU laws as members of the European Economic Area (EEA).

The Institute of Advanced Legal Studies Library collects both primary and secondary legal materials for Denmark, Finland, Norway and Sweden. Very little is held relating to Iceland, however. 

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Constitutions

English translations of all the Scandinavian constitutions and fundamental laws, as amended and with commentary, can be found at IALS in Constitutions of the countries of the world, a multi-volume looseleaf work edited by G.H. Flanz (Oceana, 1971 - ). 

HeinOnline's World Constitutions Illustrated provides English translations of the current and past constitutions together with associated laws, scholarly commentary and other documents.

Norway's constitution was adopted in 1814. An English version, as amended, is available on the website of the Norwegian Parliament, the Storting.  The constitution is also included in Norges Lover, a set of revised Norwegian laws which is held at IALS.

Sweden's constitution is made up of four fundamental laws: the Instrument of Government (1974), the Act of Succession (1810), the Freedom of the Press Act (1949) and the Fundamental Law on Freedom of Expression (1991). These are accompanied by the Parliament Act (1974), which is not classed as a fundamental law but has superior status to ordinary laws.  All are available in English on the website of the Swedish Parliament, the Riksdag.

Finland enacted a new constitution in 1999.  There is an English-language introduction to it on the Finnish Ministry of Justice website and an English translation of the constitution itself can be found on FinLex. Previously Finland had several constitutional laws, like Sweden.

Denmark's constitution was adopted in 1953. Two English versions, annotated and un-annotated, are available on the website of the Danish Parliament's EU Information Centre.

Iceland's constitution dates from 1944. An English translation amended to 1999 is available on the website of the Icelandic government.  At the time of writing, A new constitution is being drafted.  

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Legislation  

Norway

Norwegian statutes (lover) and regulations (forskrifter) are cited by title, date and number, for example Lov om beskyttelse av design av 14. Mars 2003, nr. 15; Forskrift 30. august 1991 nr. 564 om salg av arvemidler og avkall på arv til staten skal lyde. Acts maybe be referred to using a short title instead, for example Designloven (Designs Act).

Abbreviations are also used, such as al for Arveloven (Inheritance Act). At IALS, abbreviations can be looked up in Knophs oversikt over Norges rett, or Norges Lover.

Norway does not have a set of codes comparable to those of France, Italy and so on. However, it does have general statutes covering criminal law and criminal procedure, which are often described as codes. They are: Straffeloven av 22. mai 1902 nr 10 (criminal) and Straffeprosessloven av 22. mai 1981 Nr 25 (criminal procedure).

IALS Library's main source of Norwegian statutes is Norges lover, a one-volume collection of revised primary legislation produced by the University of Oslo's Law Faculty. It is published by Fagbokforlaget about every two years, with an updating supplement in the intervening period. IALS has the current edition and selected previous editions going back to 1963.

IALS does not have current Norwegian regulations, but they are available on the web (as are statutes - see below).

Limited runs of two official statutory publications are available at IALS:

  • Norsk lovtidende (published 1877 - ; in IALS 1949–62 only). This is the official gazette, published twice a month. National statutes, ordinances and regulations appear in avd. I (part I); local statutes, ordinances and regulations in avd.2.  An electronic version is available free on the Lovdata website (2001 - ).
  • Lover: vedtatt på det…ordentlige storting. Published annually, at the end of each parliamentary session. In IALS 1970/1971 - 1980/1981 only (with gaps).

We also have a five-volume set of ancient Norwegian laws, Norges gamle love indtil 1387 (published by C. Gröndahl, 1846-95).

There is a three-volume collection of revised statutes with commentary, Norsk lovkommentar, not held at IALS, published every few years by Gyldendal. Formerly it had the title Karnov: Norsk kommentert lovsamling.

 

                                                                                                                   
Electronic sources of Norwegian legislation

Statutes and regulations in force are available free on the Lovdata website, as amended, together with the official gazette, Norsk lovtidende (2001 - ).   The site also has English translations of selected instruments. Lovdata is a private foundation which was established in 1981 by the Norwegian Ministry of Justice and the Faculty of Law at the University of Oslo. 


Selected English versions of Norwegian legislation are available via the University of Oslo's website. 


Norsk lovkommentar is available online from Gyldendal, by subscription. IALS does not subscribe.

 

Sweden

Swedish statutes and regulations appear in the series Svensk författningssamling (SFS), or Swedish Code of Statutes. Each instrument is cited by year and number, for example Lag om Diskrimineringsombudsmannen (Act concerning the Equality Ombudsman) SFS 2008: 568.

Svensk författningssamling started in 1825; IALS Library has it from 1955-1983 only, together with the index, Register över gällande SFS-författningar.  The series is available free on the Lagrummet website (see below).

The most commonly-used compilation of Swedish legislation in force is the one-volume work Sveriges Rikes Lag. It is published annually by Norstedt (part of Wolters Kluwer Scandinavia).  IALS has it from 1948 onwards, with some gaps.

Revised legislation with commentary is found in the three-volume work Karnov...svensk lagsamling med kommentarer. There is also a one-volume compilation with the title Sveriges lagar. Both are published by Thomson but neither is held at IALS.

Sweden has a code of judicial procedure, called Rattegangsbalk, SFS 1942:740; it covers both criminal and civil matters. There is also a penal code: Brottsbalk, SFS 1962:700. 


The concise way in which Swedish legislation is drafted means that the travaux préparatoires are an important tool for interpretation. They are published in one of two series: either Statens offentliga utredningar (SOU) or Departementsserien (Ds). IALS has a few issues of SOU but none of Ds; however, summaries of the travaux for selected laws can be found in part II of the series Nytt juridiskt arkiv, which IALS does hold (1876 to 1990).

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Electronic sources of Swedish legislation

The official web gateway Lagrummet provides acts and regulations (lagar och förordningar) as amended, under the heading Svensk författningssamling (SFS) i fulltext. Legislation is also available on this site as originally published (i tryckt format), back to SFS 1998:306.

Selected Swedish statutes translated into English can be found on the website of the Government Offices of Sweden

Swedish subscription databases include Infotorg Juridik and Karnov-Plus. Another online source, Notisum, provides a large amount of free information, including legislation (under Lagboken), but some of the data is only available by subscription. IALS does not subscribe to any Swedish legal databases.

Finland

Finnish primary and secondary legislation is published by the Ministry of Justice in the legal gazette, Suomen säädöskokoelma (Statutes of Finland, Finnish-language edition) / Finlands författningssamling (Swedish-language edition); neither edition is held at IALS.

Official notices, circulars and similar documents are published in the official gazette, Virallinen lehti / Officiella tidningen (not in IALS).

IALS Library's source of Finnish legislation is Suomen laki, which is published annually by Talentum. A collection of Finnish legislation as amended, it is very widely used by Finnish lawyers, although it is not an official publication.  Suomen laki has been published since 1955; it is in IALS from 1995 onwards, with some gaps. We also have two old copies of the Swedish-language version, Finlands lag.

Finnish acts and decrees are cited by year and number, e.g. 503/2008 Laki rahanpesun ja terrorismin rahoittamisen estämisestä ja selvittämisestä (Act on Preventing and Clearing Money Laundering and Terrorist Financing) .

The judicial procedure chapter (Rättegångsbalk) of the general Swedish code of 1734 is still in force in Finland. It applies to both civil and criminal matters.  There is also a penal code (Rikoslaki), act 39/1889.

 

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Electronic sources of Finnish legislation

FINLEX, a free website provided by the Ministry of Justice and Edita Publishing, provides acts and decrees both in their original form and as amended. Secondary legislation is also available.  FINLEX includes English translations of many acts and decrees.

Suomen laki is available online, by subscription.  IALS does not subscribe.

Edilex, a subscription service produced by Edita Publishing, includes legislation as amended. IALS does not subscribe.

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Denmark

Danish laws (love) and regulations (bekendtgørelser) are published in the law gazette, Lovtidende.  IALS holds it  from 1939 to 1959; from 2008 onwards it is electronic-only. Most legislation appears in Afdeling A (part A); fiscal and some other instruments are published in Afdeling B; there is also an Afdeling C, containing treaties. Frequent official consolidations of legislation, called lovbekendtgørelser, appear in Lovtidende as well as the original texts. 

Administrative circulars and official guidance are published in the series Ministerialtidende, which IALS holds from 1965 to 1974. Like Lovtidende, it is electronic-only from 2008 onwards.

IALS Library's main source of Danish legislation is Karnovs lovsamling, an exhaustive compilation of statutes and regulations in force, published annually by Thomson Reuters.  It includes annotations.

Danish acts are cited by number, date and title, for example: Lov nr. 1003 af 8.10.2008 om finansiel stabilitet. Abbreviations are often used for major acts, such as Kbl for Koebeloven (Sale of Goods Act) and Aftl for Aftaleloven (Contracts Act).  Danish legal abbreviations (forkortelser) can be looked up on the Themis website, which is the work of the lawyer Ulrik Grønborg.

Denmark has a criminal code (Straffeloven). There is also a procedural code (Retsplejeloven), covering both civil and criminal proceedings.  These codes and their annual consolidations appear in Lovtidende.  IALS has an English translation of the criminal code - and other criminal legislation: Malene Frese Jensen's The principal Danish criminal acts (3rd edn, DJØF 2006).

Electronic sources of Danish legislation

Danish legislation, including consolidated laws, can be found on the official Retsinformation website.  It can be searched by title, number and/or year; select Regler for laws, regulations, official guidance, circulars and treaties.

The official gazette, Lovtidende, is available free on the internet from 2008 onwards.  It can be searched by title, number and/or year; to browse by year, click on Årgange.

Selected English versions of Danish legislation are available via the University of Copenhagen's Juraportal gateway.

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Iceland

Icelandic legislation is not held at IALS, but some can be found on the internet (see below).  For other libraries' holdings, see the FLAG Foreign Law Guide.

Acts are cited by number and year, for example the Competition Act is Lög [act] nr. 44/2005.

Iceland has a criminal code, the General Penal Code, Lög nr.19/1940.  Criminal procedure is governed by Lög nr. 19/1991 and civil procedure by Lög nr. 91/1991

Legislation is published in the Icelandic official gazette, Stjórnartídindi. There are three sections: A for acts of parliament, B for delegated legislation (regulations and decrees) and C for treaties. IALS does not subscribe.

A consolidated set of legislation is published every few years by the Ministry of Justice and Ecclesiastical Affairs (Dóms- og kirkjumálaráduneytid), under the title Lagasafn. IALS does not have it.

 

Electronic sources of Icelandic legislation

Acts are available on the website of the Icelandic Parliament, Althingi. To browse by number and year, click on Lagasafn radad eftir laganúmerum; to browse alphabetically, click on Lagasafn radad eftir lagaheitum.

The official gazette is on the internet:  parts A and B from 2001 onwards, part C from 1995 onwards.

English translations of selected acts can be found on the websites of most of the Icelandic government departments: see the Government Offices of Iceland portal.

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Law reports

Scandinavia

There are two series of law reports covering decisions from all five Scandinavian/Nordic countries:

  • Nordisk domssamling (Nordic court reports), published in Oslo by Universitetsforlaget; whole series in IALS (1958 onwards).
  • Nordiske domme i sjøfartsanliggender (Nordic decisions on maritime matters), published in Oslo by Nordisk Skibsrederforening; not in IALS.

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Norway

An English-language description of the Norwegian judicial system can be found on the Norwegian courts website.

Almost all decisions of the Norwegian Supreme Court (Norges Høyesterett) are published in Norsk Retstidende (cited as Rt). The series is held at IALS from vol.115 (1950) to  vol.130 (1965), with some gaps, and from 1999 onwards.

Selected decisions of the lower courts are published in Rettens Gang (RG). Not held at IALS Library.

There are also law reports focusing on particular areas of law, for example Dommer, uttalelser m.v. i skattesaker og skattespørsmål (Decisions and rulings etc. on tax matters). Not in IALS.

Cases are cited by law report abbreviation, year of publication and page number, for example Rt 2007 s. 4145 (s. for side, meaning page).


Electronic sources of Norwegian cases

Cases from the last four months in the Supreme Court (Høyesterett) and the six appeal courts (lagmannsrettane) are available free on the Lovdata website.  There are also two judgments translated into English on this site, dating from 2003 and 2009.  The subscription version of Lovdata includes cases from 1945 onwards (IALS does not subscribe).

The Supreme Court website provides summaries of its decisions (avgjørelser) in Norwegian from 2000 onwards.  Summaries of very recent cases are available in English.

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Sweden

The Swedish courts website provides an English-language introduction to the judicial system.

Decisions of the Supreme Court (Högsta domstolen) are published by Norstedt in Nytt juridiskt arkiv: Avd. I (part I), which is cited as NJA. The entire series is held at IALS (1874 - ).

Decisions of the six courts of appeal (Hovrätterna) from 1980 onwards appear in Rättsfall från hovrätterna (RH; not in IALS). Earlier cases can be found in Svensk juristtidning (SvJT) , which IALS holds from vol. 3 (1918) onwards.

Cases from the  Supreme Administrative Court appear in Regeringsrättens årsbok, those from the Labour Court in Arbetsdomstolens domar and those from the Market Court in Marknadsdomstolens avgöranden. IALS does not subscribe to any of these series, however.

Swedish cases are cited in the same way as Norwegian ones, e.g. NJA 2006 s.657.

 

Electronic sources of Swedish cases                                                                                                                      Top of page 

Selected Supreme Court decisions (avgöranden) are available on the Court's website from 2003 onwards.

The official Lagrummet website includes a searchable database of case summaries, covering the Supreme Court, appeal courts and other higher courts. 

The commercial database Notisum provides a large collection of free case summaries from the Supreme Court, appeal courts and special courts; the dates available vary from court to court.  The case summaries can be accessed via the Notisums Lagbok page: click on Regelsamling, then on Rättsfall and select the required court.   Much more case law is available to subscribers.   Non-subscribers can order individual cases from Notisum for a fee.

The Rättsbanken subscription database, mentioned above, also includes case law.  IALS subscribes to neither Notisum nor Rättsbanken.

 

Finland                                                                                                                                                                   Top of page

An English-language introduction to Finland's judicial system is available on the Finnish courts website.

The Supreme Court (Korkein oikeus in Finnish, or Högsta domstolen in Swedish) publishes selected decisions in its yearbook, Korkeimman Oikeuden ratkaisuja (Swedish title Avgöranden av Högsta domstolen). The Supreme Administrative Court (Korkein hallinto-oikeus, or Högsta forvaltningsdomstolen) has its own yearbook: Korkeimman hallinto-oikeuden vuosikirja (Swedish title Högsta förvaltningsdomstolens årsbok).   IALS holds neither series.  

Finnish court decisions may be found at IALS in the journals Defensor legis (in IALS 1920-1958 and 1960 - ) and Lakimies (in IALS 1962 - ).

Supreme Court cases are cited by the abbreviation KKO (HD in Swedish), the year and the case number, for example KKO:2007:211. Before the mid-1980s the part number of the Yearbook is also given, with hyphens instead of colons, for example KKO:1977-II-76.

Supreme Administrative Court cases are cited by the exact date and the case number, for example 29.12.2006/3616. For cases published in the Court's yearbook, citations take the form KHO: 2005:87.

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Electronic sources of Finnish cases

The free FINLEX website, run by the Ministry of Justice and Edita publishing, includes a large collection of cases from the Supreme Court, Supreme Administrative Court, the appeal courts, the regional administrative courts, the Market Court, the Labour Court and the Insurance Court. The extent of the available data varies from court to court.  FINLEX also provides a database of references to case law in secondary legal literature.

The Edilex subscription database, mentioned above, includes case law.

 

Denmark

English-language information about the judicial system can be found on the Danish Courts website.

The main printed source of Danish cases is the weekly title Ugeskrift for retsvæsen, cited as UfR (or simply U). Originally published by Gad, it is now a Thomson title. It includes all decisions of the Supreme Court (Højesteret), together with selected decisions of the two high courts (Østre Landsret and Vestre Landsret) and the Maritime and Commercial Court (Sø- og Handelsretten). IALS has virtually the entire series (1874 -  ; some missing issues in the 1920s, 30s and 40s).

Tax cases are reported in Tidsskrift for skatter og afgifter and cases from the labour courts in Arbejdsretligt Tidsskrift (neither of which is in IALS) .

Electronic sources of Danish cases                                                                                                                    Top of page

The Supreme Court (Højesteret) website makes available the Court's decisions from September 2009 onwards (it also provides summaries from June to August 2009).

The Maritime and Commercial Court (Sø- og Handelsretten) has a case database on its website (2002 - ).

Retsinformation.dk includes a database of administrative decisions (afgørelser) going back many years.

Forsikrings- og erstatningsretlig domssamling (FED), a collection of insurance and compensation decisions, allows non-subscribers to search the database and download up to three cases.

The Juraportal gateway lists Danish subscription databases and free websites, with links. Click on "Facts" for a description of each resource (in Danish).  Most of the free resources listed on this site are the decisions of official boards and tribunals - see Anke- og klagenævn

An online version of the law report Ugeskrift for retsvæsen is available from Thomson by subscription.

IALS does not subscribe to any Danish case databases.

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Iceland

Some information about the Supreme Court of Iceland (Hæstiréttur Íslands), including its composition and procedures, can be found in English on the Court's website.

Icelandic law reports are not held at IALS.  For printed sources in other UK libraries, see the FLAG Foreign Law Guide.

All decisions of the Supreme Court are published, together with the first instance cases, in the series Hœstaréttardómar (Supreme Court Decisions). 

Electronic sources of Icelandic cases

Supreme Court decisions can be found on the Court's website. District court decisions are available on the website of the Judicial Council.

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Books

IALS Library holds books about Scandinavian law in the vernacular languages, in English and in other European languages (notably German). However, the collection includes very little which is solely about Icelandic law. 

A selection of English-language titles are listed below; refer to the Library Catalogue for our full holdings.

Scandinavia

Zweigert, Konrad, and Kötz, Hein, Introduction to comparative law, (3rd edn, OUP 1998), ch. 19

Nergelius, Joakim, Constitutionalism : new challenges: European law from a Nordic perspective (Martinus Nijhoff 2008)

Hansen, Jesper Lau, Nordic company law: the regulation of public companies in Denmark, Finland, Iceland, Norway, and Sweden (DJØF 2003)


Hansen, Jesper Lau, Nordic financial market law: the regulation of the financial services in Denmark, Finland, Iceland, Norway and Sweden (DJOF 2003)

Melby, K. (ed.) et al, The Nordic model of marriage and the welfare state (Nordic Council of Ministers 2000)

 

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Norway

Redden, Kenneth Robert (ed.), Modern legal systems cyclopedia (W.S. Hein 1984 - ), vol. 4, ch.6

Bø, Bente Puntervold, Immigration control, law, and morality : visa policies towards visitors and asylum seekers : an evaluation of the Norwegian visa policies within a legal and moral frame of reference (Unipub, c.2002)

Hellum, Anne (ed.), Birth law (Scandianvian University Press 1993)

Smith, Lucy, Children and parents : the relationship between children and parents according to Norwegian law (Ad Notam 1991)

Sweden

Redden, Kenneth Robert (ed.), Modern legal systems cyclopedia (W.S. Hein 1984 - ), vol. 4, ch.10

Carlson, Laura, The fundamentals of Swedish law : a guide for foreign lawyers and students (Studentlitteratur, 2009)

Eklund, Ronnie, Swedish labour and employment law: cases and materials (Iustus Förlag, 2008)

Lindner, Michael G., et al, Swedish commercial legislation (Norstedts Juridik c.2007- )

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Finland

Redden, Kenneth Robert (ed.), Modern legal systems cyclopedia (W.S. Hein 1984 - ), vol. 4, ch.4

Husa, Jaakko, The constitution of Finland : a contextual analysis (Hart 2010)

Pöyhönen, Juha, An Introduction to Finnish law, 2nd ed. (Kauppakaari 2002)


Bruun, Niklas, Intellectual property law in Finland (Kauppakaari 2001)

 

Denmark

Redden, Kenneth Robert (ed.), Modern legal systems cyclopedia (W.S. Hein, 1984 - ) vol. 3, ch. 2(A), section 2

Langsted, Lars Bo, Criminal law in Denmark (Kluwer Law International 2011)

Werlauff, Erik, Civil procedure in Denmark ( Kluwer Law International c2010)

Hasselbalch, Ole, Labour law in Denmark (Kluwer Law International 2010)

Iceland

Redden, Kenneth Robert (ed.), Modern legal systems cyclopedia (W.S. Hein 1984 - ) vol. 4, ch.4(A)

Stefan Mar Stefansson, The EEA agreement and its adoption into Icelandic law (Universitetsforlaget c.1997)


Eser, Albin, et al (ed.s), Old ways and new needs in criminal legislation : documentation of a German-Icelandic Colloquium on the Development of Penal Law in General and Economic Crime in Particular (Max-Planck-Institut für Ausländisches und Internationales Strafrecht 1989)


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 Journals

IALS subscribes to the following Scandinavian law journals (the list excludes e-journals and a few very old print series - see catalogue for full holdings): 

Scandinavia

Nordisk administrativt tidsskrift (In IALS 1960- )

Nordisk tidsskrift for kriminalvidenskab (in IALS 1967-68, 1975 - )

Scandinavian studies in criminology (in IALS 1965-1993)

Scandinavian studies in law (whole series in IALS, 1957 - )

Tidsskrift for Rettsvitenskap, abbreviated as TFR (whole series in IALS, 1888 - )                                          Top of page  

 

Norway

Lov og rett: norsk jurdisk tidssdrift , abbreviated to LoR (whole series in IALS, 1962 - )

 

Sweden

Juridisk tidskrift vid Stockholms universitet: JT (in IALS 1991/92, 1997/98 - )

Advokaten, formerly Tidskrift för sveriges advokatsamfund (in IALS 1936 - )

Svensk juristtidning (in IALS 1918 - ; earlier years incomplete)

Förvaltningsrättslig tidskrift (whole series in IALS, 1938 - )

 

Finland

Lakimies (in IALS 1962 - ): published by the Finnish Bar Association; has abstracts in English (and a few English articles).

Defensor Legis (whole series in IALS except vol. 40, 1959)

Tidskrift utgiven av Juridiska Föreningen i Finland, abbreviated to JFT (in IALS 1951 - )

 

Denmark

Juristen : udgivet af Danmarks jurist-og okonomforbund (in IALS 1938 - ; see Library catalogue for title variations)

 

Iceland

The Library does not subcribe to any Icelandic law journals.

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Research guides and bibliographies

The Globalex website (New York University School of Law) has research guides for each Scandinavian country.

Winterton, Jules, and Moys, Elizabeth, Information sources in law, 2nd ed., 1997.  Includes a chapter on each country.

Strømø, Hanne E, and Kongshavn, Halvor, Nordic legal festschriften : a bibliography of the essays written in English, German and French until 1999, 1999.

The Royal Danish Library's website includes a searchable web version of the Dansk Juridisk Bibliography (Danish Legal Bibliography), 1988- .

The University of Bergen Law Library has compiled a bibliography of Norwegian law in foreign languages.

 

Online resources

The Foreign Law Guide database is available at IALS (see Electronic Law Library). It includes outlines of the legal systems of each of the five Scandinavian countries, together with information about their legal publications and websites.  It mentions English-language sources, where available.

The website of the Royal Danish Library provides lists of online law resources.

Juraportal,  a gateway site produced by the University of Copenhagen's law library, provides a well-organised collection of links to law websites from all over Scandinavia.  Juraportal is available in English as well as Danish.

(N.B. Electronic sources of legislation and case law are detailed in the relevant sections above)

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