Delict
Delict is a term in civil law jurisdictions for some kind of legal wrong, but its meaning is very different from one jurisdiction to another. Aside from mixed common law systems such as Scotland, South Africa, Louisiana and the Philippines, delict is generally
not a legal term used in common law jurisdictions. The exact meaning of delict varies between legal systems but it is always centred on the Roman law idea of wrongful conduct. In Spanish law,
delito is any breach of criminal law. In Italian law,
delitto penale, is the same concept, but
delitto civile, like delict in Scots law, is an intentional or negligent act which gives rise to a legal obligation between parties even though there has been no contract between them, akin to common-law tort. German-speaking countries use the word
Delikt to refer to criminality, but
Deliktsrecht is a branch of civil law. In French law,
délit penal is a misdemeanor, while
délit civil, again, is a tort.