This presentation thus seeks to investigate the active engagement of a non-Western society during 19th and early 20th century with a legal tradition they identified as simultaneously more powerful and sharply at odds with its own. It seeks to develop commonalities and differences in the colonial encounter through a comparison of the Iranian experience with other Muslim experiences, but in particular with the very different Japanese approach. Individuals in all three of these cultural spheres sought to capture what made the West so powerful and transpose that essence at home. They all identified the Western legal tradition as a particularly important component of modernity and an enduring source of strength.

The relative hostility in the Islamic world to transposed legal norms is often explained with reference to the peculiar characteristics of its religious dogma and continues to define and hinder legal reform and constitutional debates. This enduring attitude sharply contrasts with a receptivity borne of necessity shown first in Japan, and later in China, Korea and elsewhere.