Jurisdiction coverage, down to state level

“US law” and “UK law” are fictions — contracts live under the law of a specific place. A rent-review clause that’s standard in England is void in Victoria; Scotland isn’t England, Northern Ireland isn’t either; Quebec and Louisiana are civil law; Hong Kong is common law with its own ordinances. The engine carries 73 jurisdictions across 9 legal systems and reads 22 classes of document — each jurisdiction with its own statute and case-law layer, composed federal and state where federations demand it.

Business tenancy security of tenure, unfair terms control, and the modern penalty doctrine.

• Landlord and Tenant Act 1954 Part II (renewal rights and contracting-out)
• UCTA 1977 reasonableness on exclusion clauses
• Dilapidations exposure and schedule-of-condition protection (LTA 1927 s 18)
• Penalty clauses after Cavendish v Makdessi
• Trade Secrets Regulations 2018 for confidentiality terms

A separate mixed legal system — English boilerplate in a Scottish lease is a drafting error our engine flags.

• Irritancy (not forfeiture) with its mandatory statutory notices
• Tacit relocation and notice-to-quit timing
• Real rights under the Leases Act 1449; registration of 20+ year leases
• No doctrine of consideration; 5-year prescription
• LBTT (not SDLT), including three-yearly lease returns

Not a copy of England — NI’s own devolved layer.

• Business tenants cannot contract out of security of tenure (Business Tenancies (NI) Order 1996) — the opposite of England
• Unfair dismissal after one year (not two) + the unique FETO fair-employment monitoring regime
• Divorce remains fault-based — the 2020 no-fault reforms never extended to NI
• Registry of Deeds titles, fee farm grants, Enduring (not Lasting) Powers of Attorney

A federal layer (UCC, DTSA, Federal Arbitration Act) composed with every state’s own rules.

• California: employee non-competes void (B&P §16600) — and the engine knows it
• New York: GOL choice-of-law thresholds, no UTSA, Yellowstone traps
• Louisiana: civil law — no UCC Article 2, redhibition, strict non-compete statute
• Texas: mandatory reformation; Delaware: strict textualism and Chancery doctrine
• Limitation periods and covenant rules for all 50 states + DC

Federal consumer law composed with state retail-lease regimes that override your lease.

• Australian Consumer Law: non-excludable guarantees, unfair contract terms penalties
• Victoria: 5-year minimum term, ratchet clauses void, land tax non-recoverable (RLA 2003 ss 21/35/50)
• NSW disclosure obligations and bond scheme; Queensland compensation rights
• Penalty doctrine after Andrews and Paciocco
• State-by-state proportionate liability and contracting-out rules

The good-faith revolution applies to every contract — and Quebec is civil law.

• Good faith and honest performance (Bhasin, Callow, Wastech)
• Interest Act s 4 (monthly rates cap at 5%/yr) and the criminal interest rate
• Commercial tenancies statutes and distress rules by province
• Quebec: Civil Code regime, adhesion-contract controls, French-language requirements

Full legal layers, live in the engine.

• South Africa: huur gaat voor koop, Conventional Penalties Act, CPA thresholds, POPIA
• Nigeria: Land Use Act consent requirements, Lagos Tenancy Law advance-rent limits, NDPA 2023

Common law preserved under the Basic Law — with sharp local edges the engine knows.

• All land is leasehold from the Government; Deeds of Mutual Covenant bind every occupier
• Companies Ordinance (Cap 622): one-month charge registration; solvency-test financial assistance; Takeovers Code 30% trigger
• Employment’s 418 rule; MPF severance offset abolished 2025
• Sanctioned offers, HKIAC arbitration + Mainland enforcement; no general consumer cooling-off

Legal Case Analyst (legalcaseanalyst.com) provides automated, preliminary decision-support analysis. It is not a law firm, does not provide legal advice, and no solicitor/attorney–client relationship is created by its use. For legal advice, consult a licensed practitioner in your jurisdiction — every report can connect you with one. Contact: hello@legalcaseanalyst.com