Unseen Agencies of Transformation
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Intro: Legal Reforms as Reorganisation of Order

The colloquy “Unseen Agencies of Transformation” explores how non-Western legal systems transformed during the 19th and early 20th centuries – not as passive recipients of Western legal models, but through contested, negotiated, and often locally driven processes of reform and adaptation.

In December 2022, the symposium “Legal Orders under Pressure: Non-Western Experiences of Legal Transformations in the 19th and early 20th Centuries” critically reassessed what it means for legal systems to modernise under the pressure of Western influence and internal reform1. While modern legal history is often framed in terms of Western legal expansion – highlighting codification, constitutional moments, and the transplantation of foreign legal models – this colloquy argues that such narratives obscure the lived experience of legal change and the local rationalities that shaped it.

» Legal change must be understood not only in terms of institutional design or textual production, but also in terms of how people used, contested, and reinterpreted law in their social worlds «

Global history has encouraged scholars to view the “long nineteenth century” as a unified temporal framework that captures global transformations of commerce, empire, nation, and ideas. Yet, applying this historiographical turn to legal history remains challenging. A key reason for this is the continued emphasis on the formal adoption of Western legal codes, often in the late nineteenth century, particularly in relation to unequal treaties. This focus obscures earlier, more gradual legal developments that emerged from within each society. To overcome this limitation, we need to turn to legal practice itself – examining transformations in customary norms, the involvement of various actors in shaping legal reasoning, and the cross-regional exchanges that shaped these changes.

By focusing on legal practices involving Christian, Muslim, and Jewish merchants as well as local bureaucrats, we can more accurately capture the complexity and diversity of legal modernisation outside the West. Legal reform in these cases is more clearly understood in terms of regionally embedded processes of rationalisation, dispute settlement, and the reorganisation of order, which preceded the formal enactment of modern legal codes.

Perspectives on the world depend greatly on where you stand: Shintei – Chikyu Bankoku Hozu (Square Map of all the Countries on the Globe), 1853, source: Wikimedia Commons/Geographicus Rare Antique Maps.

The westernisation of law should not be reduced to a single moment of rupture – such as the promulgation of a civil code or a treaty – nor should it be understood solely as legal reception. Instead, we highlight the agency of local actors, the continuing importance of customary and religious law, and the tensions between official reforms and everyday legal practices. Legal change must be understood not only in terms of institutional design or textual production, but also in terms of how people used, contested, and reinterpreted law in their social worlds.

The three case studies presented – the Ottoman Balkans, Thailand, and Ethiopia – illustrate this approach by foregrounding the internal dynamics of legal transformation in non-Western contexts. These studies show how non-Western societies engaged with legal modernity not as passive recipients of European norms, but as active participants negotiating legal change on their own terms.

Local Agency, Tradition as Archive, and Selective Engagement

Ivelina Masheva’s text “Merchants, Local Elites, and New Commercial Litigation in the Ottoman Balkans” shifts the focus from central legal reforms to local dynamics. By examining how commercial courts emerged in the Ottoman Balkans in the 1840s and 1850s in response to local demands for more efficient legal mechanisms, Masheva shows that the institutionalisation of commercial litigation was a negotiated process shaped by competing interests at multiple levels. This bottom-up perspective challenges the assumption that legal modernisation in the Ottoman Empire was exclusively state-driven and shows how legal practices evolved organically from the initiatives of provincial actors. It enriches our understanding of Ottoman legal pluralism and invites comparison with other regions where local agency also drove legal innovation.

Surutchada Reekie and Adam Reekie’s text “Siam’s Tectonic Legal Reform Process” examines the role of the Three Seals Code in shaping legal norms. Contrary to the common view that traditional Thai law was replaced by Western-style codification, it argues that the Three Seals Code served as a living legal archive that continued to inform legal reasoning well into the modern period. It emphasises that legal modernisation in Thailand was not a simple replacement, but a hybrid process shaped by indigenous legal traditions, foreign (especially British) advisers, and commercial imperatives. This dynamic account reframes Thai legal reform as a negotiation between tradition and modernity.

Hailegabriel Feyissa’s text “European Imperialism and Legal Transformation in 20th Century Ethiopia” offers a two-stage framework for understanding Ethiopian legal reform. Distinguishing between early 20th-century constitutional initiatives (such as the 1931 Constitution) and later codification efforts (such as the 1960 Civil Code), Feyissa critiques the dominant view of Ethiopia’s legal modernisation as either entirely endogenous or externally imposed. He shows that Ethiopia’s legal transformation was shaped by selective engagement with foreign models, including Japan’s Meiji Constitution, and active domestic debates about sovereignty and legitimacy. He also highlights the limited attention given to Ethiopian legal history in scholarly discussions.

Rethinking Legal Transformations Through Practice and Pluralism

Taken together, these contributions offer more than region-specific insights – they contribute to a reconceptualisation of legal modernity itself. They show that economic rationality, moral imagination, and institutional experimentation emerged in various forms throughout the non-Western world, often well before or independently of direct colonial rule or Western intervention. This challenges the dominant historiography that associates modern law with codification and centralised state power, and opens space for a more pluralist, actor-centred, and practice-based understanding of legal change.

In sum, legal reforms in the Ottoman Empire, Thailand, and Ethiopia cannot be explained simply as a response to pressure from Western countries or as a mere imitation of European legal systems. Rather, they were a multi-layered process of restructuring legal orders, deeply rooted in local realities and involving a variety of actors – judges, merchants, bureaucrats, lawyers, national and local politicians – in creative and controversial ways. By reconstructing the process of formation of these alternative modern legal systems, we can deepen our understanding of the history of law and develop new conceptual tools for thinking about law and order that are rooted in each region and history.

  1. Online symposium of the Max Planck Research Group Translations & Transitions, 7–9 December 2022, organised by the Chair for Globalisation and Legal Pluralism, Faculty of Law, University of Vienna, Austria, together with the Max Planck Institute for Legal History and Theory, Frankfurt am Main, Germany. ↩︎
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Makiko Hayashi, “Introduction: Legal Reforms as Reorganisation of Order,” ant.e, September 2025, https://ante-blog.univie.ac.at/article/introduction-legal-reforms-as-reorganisation-of-order/.
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Merchants, Local Elites, and New Commercial Litigation in the Ottoman Balkans

The reforms of the legal and judicial system during the so-called Tanzimat (lit. “reorganization”) period of the Ottoman Empire have been the focus of scholarly debate from a range of perspectives. While early scholars interpreted Ottoman development in the Tanzimat period through the westernization paradigm, from the 1970s onwards a new generation of historians started to reframe the reforms. They placed the Tanzimat within the context of the Ottoman government’s political programme and defined the reforms as part of a “statist policy of voluntary modernization”.1 Still, there was a consensus in scholarship that the reforms were a “top-down and outside-in” enterprise that often failed to be implemented due to lack of “vigorous popular support”.2

A new turn in scholarship has given rise to innovative approaches to Ottoman judicial reforms, shifting the focus from the imperial centre to the provinces, and illuminating the crucial role that provincial elites and local Ottoman bureaucrats played in implementing and shaping 19th century reforms.3 Building on this growing body of scholarship, my blog post conceptualizes the establishment of the first commercial courts in the Ottoman Balkans as a dynamic process involving various social groups on both central and local levels.

Establishing Commercial Courts: The Role of Provincial Authorities

Following the establishment of the Istanbul commercial court in 1840, such specialized judicial bodies were gradually established in major commercial centres in the Ottoman Balkans, starting with Edirne and Salonica in 1847.4 Initially, the jurisdiction of these institutions was open only to foreigners and Ottoman privileged (beratlı) merchants.5 From the early 1850s onwards, commercial courts also began to appear in mid-sized Balkan towns, such as Tırnova, where one was created in 1852.

The initiative for the Tırnova court came from the local authorities, who justified their request with problems in the adjudication of commercial disputes in the local council (meclis) and the kadi court. Commercial disputes were not only taking too long to resolve, due to indecision and opposition (tereddüd ve muhalefetler), but decisions also often failed to comply with the newly adopted Ottoman Commercial Law (1850). As a result, local authorities claimed, merchants found themselves compelled to bring even insignificant cases to be settled in Istanbul, incurring considerable financial burden on both sides. To eliminate these problems, the head district official (kaymakam) proposed to establish a commercial court in their city to resolve disputes according to commercial law and not Islamic law.6

Localizing reforms: This Bulgarian translation appeared 6 years after the original Appendix to the Ottoman Commercial Code (1860/1866). Title page of the translation by Stoil Popov, held by the Bulgarian National Library; photo by Ivelina Masheva.

The most detailed information available so far about establishing early commercial courts in the Ottoman Balkans concerns the Varna Commercial Court. The request for the establishment of a commercial court came from the local customs official in March 1857. It pointed out that disputes between Ottoman and foreign merchants were being resolved by the customs official, but the growing number of cases required the establishment of a specialized judicial institution. The Varna commercial court was established in late 1857, closely following the model and organization of the Istanbul Commercial Court.7

When Local Politics Block Reform: The Sofia Case

In 1855, there was an attempt to establish a commercial court in Sofia. In January 1855, two Bulgarian merchants – Hadzhi Mano Stoyanov and Anastas Todorov – addressed the Ottoman Supreme Council of Judicial Ordinances (Meclis-i Vâlâ-i Ahkâm-i Adliye) with a request to establish such an institution in their city.8

A letter from Castaing, the French diplomatic agent in Sofia, dated 21 April 1855, sheds light on the outcome of the initiative. It confirms that the driving force behind the demand were local Ottoman non-Muslim merchants (Christians and Jews). However, the initiative failed due to disagreement between non-Muslim notables and the head district official over the ethnoreligious composition of the court – the kaymakam insisted on a Muslim “predominance”, which was unacceptable to the Christians and the Jews.9

This example is indicative of the importance of local politics. While local support ensured the successful establishment of a commercial court in the cases described earlier, lack of consensus between local stakeholders in Sofia resulted in (temporarily) blocking the reform. Moreover, the case allows us to speculate that both Muslims and non-Muslims were very sensitive to who applied the law and whether their ethnoreligious group was fairly represented in judicial bodies.

In December 1856, the local council of Filibe (nowadays Plovdiv) also addressed the Sublime Porte with a request to open a commercial court in the city.10

Merchants as Reformers: The Case of Eski Zaara

A case that illustrates the role of merchants in commercial jurisdiction reforms in the Ottoman Balkans was the attempt to establish a commercial court in Eski Zaara (nowadays Stara Zagora). In January 1859, the local Bulgarian merchant A. Hadzhistoyanov informed two Bulgarian merchants residing in Constantinople that the local traders, “Turks, Christians, and Jews”, had jointly decided to petition the government with a request to open a commercial court in the town. The preliminary approval from the imperial centre, however, did not fully meet the expectations of the Eski Zaara merchants for a judicial institution open to all categories of merchants, and not only to beratlı merchants.11 Local merchants lost interest in the initiative, and consequently, a commercial court was not established.

Despite its failure, the case has several interesting points. First, contrary to the Sofia case, here we see cross-communal collaboration. Moreover, it also points to the desire of provincial merchants to open some of the legal and judicial privileges of the beratlı merchants to the rest of the Ottoman mercantile class.

Agents of Reform in Their Own Right

Looking at the role Ottoman merchants, community leaders, and local authorities played in the transition to modern Western commercial law and the establishment of modern commercial litigation, they appear more as agents of reform in their own right than as mere passive recipients of a top-down reform. Their support was of paramount importance for the successful application of reforms, while opposition and dividedness resulted in failed or delayed implementation. Furthermore, examining the process of the establishment of early commercial courts in the Ottoman Balkans leads to the conclusion that the spread of the commercial courts network in the 1850s Balkans was driven by local demand rather than centrally mandated.

Though by no means exhaustive or systematic in nature, the evidence presented allows us to begin questioning the narrative of the Tanzimat reforms in commercial law and commercial jurisdiction as a “top-down and outside-in” enterprise that lacked “vigorous popular support”.12 While not denying the crucial role of the Ottoman central government and its key reformist figures, nor that of Western diplomatic pressure, it nevertheless seems necessary to reassess their exclusivity. Taking into account the role of Ottoman merchants, community leaders, and provincial authorities would allow for a more nuanced and inclusive approach that more faithfully reflects the complexities of Ottoman reality, especially in the economic and commercial sphere, where actions and interactions on the local, imperial, and international levels have always been deeply entangled.

  1. Kemal Karpat, “Transformation of the Ottoman State, 1789–1908,” International Journal of Middle East Studies 3, no. 3 (1972): 258–9. ↩︎
  2. Roderic H. Davison, Reform in the Ottoman Empire 1856-1876 (Gordian Press, 1963), 406. For another revisionist perspective on this concept, see: Milen Petrov, “Everyday Forms of Compliance: Subaltern Commentaries on Ottoman Reform, 1864–1868,” Comparative Studies in Society and History 46, no. 4 (2004): 730–59. ↩︎
  3. Mafalda Ade, “Ottoman Commerical Law and Its Application in Aleppo Province (1850-1880),” in Merchants in the Ottoman Empire, ed. Suraiya Faroqhi and Gilles Veinstein (Peeters, 2008), 243-58; Milen Petrov, “Tanzimat for the Countryside: Midhat Paşa and the Vilayet of Danube, 1864-1868” (PhD diss., Princeton University, 2006); M. Safa Saraçoğlu, Nineteenth-Century Local Governance in Ottoman Bulgaria Politics in Provincial Councils (Edinburgh: Edinburgh University Press, 2018); Yonca Köksal, The Ottoman Empire in the Tanzimat Era: Provincial Perspectives from Ankara to Edirne (Routledge, 2019);  Zülâl Muslu, “Ottoman Mixed Commercial Courts,” in Max Planck Encyclopedia of International Procedural Law, ed. Hélène Ruiz Fabri (Oxford University Press, 2023). ↩︎
  4. Ekrem BuğraEkinci, Osmanlı Mahkemeleri: Tanzimat ve Sonrası (Arı Sanat, 2004), 103. ↩︎
  5. In the early 1800s, the Ottoman government created two categories of privileged merchants: Avrupa tüccarı (for non-Muslims) and Hayriye tüccarı (for Muslims), granting them economic, legal and judicial rights similar to those of foreigners. For more information see: Bruce Masters, “The Sultan’s Entrepreneurs: The Avrupa Tüccaris and the Hayriye Tüccaris in Syria,” International Journal of Middle East Studies 24, no. 4 (1992): 579–97. ↩︎
  6. Presidency of the Republic of Türkiye, Directorate of State Archives (BOA), collection Meclis-i Vâlâ, dossier 249, case 20. ↩︎
  7. BOA, collection İrâde – Meclis-i Vâlâ, dossier 382, case 16745; BOA, collection Sadâret Mektubî Kalemi – Meclis-i Vâlâ, dossier 93, case 5; BOA, collection Sadâret Mektubî Kalemi – Nezâret ve Devâir, dossier 252, case 94; collection Sadâret Mektubî Kalemi – Mühimme Kalemi, dossier 128, case 31; ibid., dossier 124, case 20. ↩︎
  8. BOA, collection Sadâret Mektubî Kalemi – Nezâret ve Devâir, dossier 130, case 35. ↩︎
  9. Archives du Ministère de l’Europe et des Affaires étrangères, Centre des Archives diplomatiques de Nantes, 166PO/D85/1, p. 104. Letter from Castaing, French agent in Sofia, to Benedetti, chargé d’affaires of France in Constantinople. Letter no. 13, 21 April 1855. ↩︎
  10. BOA, collection Sadâret Mektubî Kalemi – Nezâret ve Devâir, dossier 130, case 27. ↩︎
  11. Bulgarian Historical Archive, National Library “Saints Cyril and Methodius”, fonds 6, archival units IA5115–IA5141; see also Evguenia Davidova, Balkan Transitions to Modernity and Nation-States: Through the Eyes of Three Generations of Merchants (1780s–1890s) (Brill, 2013): 166. ↩︎
  12. Roderic H. Davison, Reform in the Ottoman Empire, 1856-1876 (Princeton Legacy Library, 2016): 406. ↩︎
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Ivelina Masheva, “Merchants, Local Elites, and New Commercial Litigation in the Ottoman Balkans,” ant.e, September 2025, https://ante-blog.univie.ac.at/article/merchants-local-elites-and-new-commercial-litigation-in-the-ottoman-balkans/.
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Siam’s Tectonic Legal Reform Process

» It is appropriate to think of law in South East Asia geologically, as a series of layers each of which overlays the previous layers without actually replacing them, so that in places, due to tectonic shifts, the lower layers are still visible, although not perfectly distinguishable from each other. « – Andrew Harding1

What does it mean for a country’s legal system to modernise without colonisation? Applying Professor Harding’s geological analogy, the answer for Siam seems to lie beneath tectonic layers of law, culture, and reform – with the willingness to push forward change being the main tectonic force that caused the shifts.

Siam’s law reform in the 19th and early 20th centuries may be thought of as comprising two main parts: the reform of substantive law and the reform of the judicial system. Focusing on the first, we argue for a more comprehensive understanding of the reform process, to encompass the true complexities involved. Rather than a seamless transition from traditional to modern law, Siam’s legal reform may be thought of as piecemeal and shaped by multiple, overlapping influences. Accordingly, any research into the reform process should accommodate the many spheres of influence, not only from the obvious source that is pressure from colonial powers, but also from the much less discussed latent impetus.

For this blog post, we have chosen two aspects that highlight this complexity: our presupposition of the nature of “traditional law” and the under-acknowledged influence of the people who personified the law reform.

The Elastic Nature of Siam’s Traditional Law

There is no single accepted narrative of Siam’s legal history, and the roles that various factors played in the country’s legal development continue to be debated. However, for the purpose of this blog post, it is useful as a starting point to draw on the work of the late eminent Thai scholar Professor Preedee Kasemsup,2 according to whom Thai legal history may be divided into two broad eras: “pre-modern” or “traditional” law, and “modern” law.3 The former refers to the laws of previously ruling states in the geographical area of today’s Thailand (the Sukhothai, Ayutthaya and early Bangkok periods), while the modern era began with the reform period and continues to present-day Thailand.4

The progression from traditional law to modern law certainly hinges on the linear notion that the country moved from one broad type of “law” to another. This view was challenged when Baker and Phongpaichit recently argued that Siam’s traditional law, known as the Three Seals Code, should not be seen as legislation, but as an archive of socio-legal history. According to Baker and Phongpaichit, it would be illusory to impose our modern understanding of law and law-making on historical texts such as the Three Seals Code which, in their view, should be viewed as a historical archive reflecting the gradual accumulation of court rulings and decrees, as well as poetry, word play, and homily.5

More than “just” law: the Three Seals Code includes not only court rulings and decrees, but also poetry, word play and homily. Here displayed at the National Museum, Bangkok, Thailand.

This led to their thought-provoking suggestion that the Three Seals Code perhaps should not be treated as “law”, as far as law may be broadly understood as a system of rules, since it possesses different characteristics and may serve a wider social function – such as teaching the public about desirable behaviours – rather than a narrow statutory function.6 Instead, it may be considered as an archival compilation of written evidence of the evolution of legal conceptions.

Therefore, we should adopt a more flexible analytical framework when examining Siam’s reform process and recognise the true nature and characteristics of the subjects under study within their specific contexts. Certainly, it is more convenient to compare like with like – that is, one type of “law” with another type of “law”. However, such an approach may inadvertently obscure a richer, more nuanced understanding of legal history.

But if the law itself was elastic and layered, who or what were the “tectonic forces” – i.e. the agents shaping its form and direction?

Law-Shaping Lawyers

Another layer that adds to the tectonic landscape of Siam’s law reform comes from what Alan Watson called “Law-shaping Lawyers”, by which he referred to a group of the legal elite who shape the law either through their involvement in the legislative process or through the creation of precedents or authoritative legal interpretation.7 In a context of legal transplants, which Siam’s legal reform may be seen as, Watson argued that the law which emerged from the process tended to be strongly influenced by the knowledge of this group of lawyers, by their imagination, training, and worldviews.

The case of law-shaping lawyers in Siam is most fascinating. Tamara Loos acknowledged the transnational and transcultural nature of Siam’s legal reforms, as a number of foreign legal advisers from the East and the West worked alongside Siamese lawyers in shaping and implementing various changes.8 We have also taken an interest in the roles in which lawyers from the common law world helped shape the law reform process of Siam, a civil law country.

In our work on a comparative history of the courts of justice, we found that during the reform period, many British lawyers were appointed to the highest court of the land (and also to lower courts, but judgments of these were not recorded, rendering this a difficult topic for research), sitting alongside French, Japanese, and Siamese judges.9 We argued, among other things, that their legal backgrounds and professional experiences – such as their previous work as barristers in Britain or judges in British colonial territories – may have influenced Siam’s legal development, through their methods of legal analysis and application. However, their strong common law influence during the formative years of the country’s “modern” legal era was counterbalanced by the civil law influence from the French and Japanese judges. This is but one aspect of the hybridity of Siam’s reform process.

» In a context of legal transplants, Watson argued that the law which emerged from the process tended to be strongly influenced by the knowledge of a legal elite, by their imagination, training, and worldviews. «

In another article focusing on vicarious liability law, we argued that Thailand’s current main provision on vicarious liability (section 425 of the Civil and Commercial Code) may have been an incidental legal transplant from English law, influenced by the main Siamese drafters at the time, who were educated in England.10

Other “Law-shaping Lawyers” may be found in the Law Drafting Committee (currently known as the Office of the Council of State), the Ministry of Justice, and among personnel of other government departments such as the Ministry of Foreign Affairs and the Ministry of the Interior, as well as foreign advisors to the government. Together, they established the country’s legal structure and navigated the devious course of modernisation in the shadow of colonial threats.

All these facts point to the importance of understanding the key persons behind each legal phenomenon in order to truly unpack the layers and spheres of influences affecting the change.

How Should We Approach the Multi-Layered Reform Process?

This blog post marks an early step in what we hope will be a sustained exploration of the rich and layered field of legal history. From among many facets of this complex process, we explore two aspects which yield two key lessons. The first is to be open-minded to a challenge to an accepted norm – such as the question if traditional law was “law” at all. Another lesson is to understand a process not only from its impetus, but also from the people who turn its wheels. In the case of Siam, internal motivations and domestic spheres of influence help form a wider and more holistic view of the process. An emphasis on colonial threats is never the whole story – just one tectonic force.

  1. Andrew Harding, “Comparative Law and Legal Transplantation in South East Asia,” in Adapting Legal Cultures, ed. David Nelken and Johannes Feest (Hart Publishing, 2001), 205.  ↩︎
  2. See Preedee Kasemsup, “Reception of Law in Thailand—a Buddhist Society,” in Asian Indigenous Law: In Interaction with Received Law, ed. Masaji Chiba (KIP Limited, 1986), 267–300.  ↩︎
  3. Another eminent Thai scholar who shares a similar view is Professor Kittisak Prokkati (see Kittisak Prokkati, The Reform of Thai Law under European Influences (Winyuchon, 2013), 55 (Thai language)).  ↩︎
  4. Note that other scholars may hold different views. For instance, R. Lingat divided Thailand’s legal development into four periods: the Ayutthaya period, the early Bangkok era (reign of King Rama I to early reign of King Rama IV), the Reform Period (reign of King Rama IV to reign of King Rama V), and the current period marked by the use of main codes of law (codification period). Robert Lingat, History of Thai Law (1935), 83-84 (Thai language).  ↩︎
  5. Chris Baker and Pasuk Phongpaichit, “The Child is the Betel Tray: Making Law and Love in Ayutthaya Siam,” Thai Legal Studies 1 (2021): 1-21. ↩︎
  6. Ibid. 11-13.  ↩︎
  7. Alan Watson, “Comparative Law and Legal Change,” CLJ 313, no. 37(2) (1978): 322-328.  ↩︎
  8. See Tamara Loos, Subject Siam: Family, Law, and Colonial Modernity in Thailand (Silkworm Books, 2006), 29-71. ↩︎
  9. Surutchada Reekie and Adam Reekie, “British Judges in the Supreme Court of Siam,” in Thai Legal History, ed. Andrew Harding and Munin Pongsapan (CUP, 2021), 103-121. ↩︎
  10. Adam Reekie and Surutchada Reekie, “The Long Reach of English Law: a Case of Incidental Transplantation of the English Law Concept of Vicarious Liability into Thailand’s Civil and Commercial Code,” Comparative Legal History 6, no. 2 (2018): 207-232. ↩︎
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Adam Reekie and Surutchada Reekie, “Siam's Tectonic Legal Reform Process,” ant.e, September 2025, https://ante-blog.univie.ac.at/article/siams-tectonic-legal-reform-process/.