Duty to rescue under Civil Law and Common Law?

In most common law jurisdictions such as the US, most Canadian provinces and the UK, there is no law requiring passers-by to help a person in peril. But in lots of common law jurisdictions like continental Europe, the Canadian province of Quebec and etc, there is generally a duty to rescue. For example, in the... show more In most common law jurisdictions such as the US, most Canadian provinces and the UK, there is no law requiring passers-by to help a person in peril. But in lots of common law jurisdictions like continental Europe, the Canadian province of Quebec and etc, there is generally a duty to rescue. For example, in the Quebec Charter of Human Rights and Freedoms, Section 2 "Every person must come to the aid of anyone whose life is in peril, either personally or calling for aid, by
giving him the necessary and immediate physical assistance, unless it involves danger to himself or a
third person, or he has another valid reason."

Why there is such a difference under civil law and common law? I suspect it might be because of some fundamental philosophical differences under the two system. Could anyone familiar with comparative law explain this to me?

Thanks.
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