Frederic Maitland famously defined equity in England as the “body of rules administered
by our English courts of justice which, were it not for the operation of the
Judicature Acts, would be administered only by those courts which would be known
as Courts of Equity”.1,2 One century later, Sarah Worthington would define equity in
a similar vein as the “body of rules, principles and remedies that derive from those
initially developed and administered in the English High Court of Chancery”.3 But
if these definitions may convey the impression that equity is a unique feature of the
common law tradition,4 this is far from being the case. Rather, equity has been an
equally important fixture of continental European legal history for centuries.