This might help clarify where we are in Quebec. The important bit is the burden of proof and evidence.
Inspired by the 1804 Code Napoléon, the Civil Code of Lower Canada was enacted in 1866. It had four books governing:
* Persons
* Property and its Different Modifications
* Acquisition and Exercise of Rights of Property
* Commercial Law
The Civil Code of Lower Canada remained unchanged until 1955, when changes began to be made. By the late 1980s, it was realized that a major revision was required. A new Civil Code of Quebec came into force on February 1, 1994. It contains ten books:
1. Persons (e.g.: basic individual rights, residence rules, privacy)
2. The Family (e.g.: marriage, parentage, adoption)
3. Successions (e.g.: wills, inheritance, estates)
4. Property (e.g.: possession, land boundaries, right-of-way)
5. Obligations (e.g.: contract law, civil liability (tort law), sales, leasing)
6. Hypothecs (i.e.: mortgages and the sale of land)
7. Evidence (e.g.: burden of proof, rules of evidence)
8. Prescription (i.e.: statutes of limitations)
9. Publication of Rights (e.g.: registration of property)
10. Private International Law (governs the resolution of legal issues involving persons outside Canada)
This new code integrates some concepts from Common law. It is still under debate as some of its regulations fall under the sphere of the federal government as determined by the British North America Act, 1867 (now renamed Constitution Act, 1867) and Constitution Act, 1982.