Civil Law Private Rights Translator

---
name: civil-law-private-rights-translator
name_en: civil-law-private-rights-translator
description: Use when translating, reviewing, or drafting legal English involving civil/private-law concepts whose English term depends on legal system and doctrinal function; especially civil law, capacity, agency, civil liability, force majeure, limitation/prescription, real rights, ownership, mortgage, contract, obligation, consideration, privacy, personal data, tort, negligence, and strict liability.
---
# Civil Law Private Rights Translator

## R - Reading

Scope signals:

- civil law may refer to private law, the civil-law legal family, or secular/state law.
- Act of God and contingency should not be treated as automatically identical to force majeure.
- Covers capacity, agency, civil liability, limitation, real rights, contract, privacy, personal data, tort, negligence, and strict liability.

## I - Interpretation

Civil-law translation is especially vulnerable to false equivalence. The same English expression may mean a branch of private law, a legal system, or secular state law. The same Chinese concept may map differently in common law, civil law, PRC law, German law, EU data law, or contract practice.

The skill therefore asks: what legal institution is being translated, what legal system gives it meaning, what legal effect follows, and whether a seemingly familiar English term is too narrow, too broad, or from another doctrinal family.

## A1 - Past Application

Key private-law distinctions include:

- civil law as 民法, 大陆法, or 国法.
- capacity as identity/status, legal capacity, capacity for civil juristic acts, criminal capacity, corporate capacity, or testamentary capacity.
- agency as agreement-based, law-based, apparent/ostensible authority, or government agency in a different sense.
- force majeure, Act of God, and contingency as related but non-identical risk concepts.
- limitation, prescription, statute of limitation, and statute of repose as different time-bar structures.
- consideration, cause, and counter-performance as system-sensitive contract concepts.

## A2 - Future Trigger

Invoke this skill for:

- civil code, contract, tort, property, privacy, data, succession, adoption, or private-law translation;
- review of legal opinions or bilingual clauses involving capacity, agency, liability, limitation, force majeure, consideration, real rights, ownership, mortgage, tort, negligence, or strict liability;
- questions asking whether a common-law term can be used for a PRC/civil-law concept.

Do not invoke for litigation procedure unless the issue is about the underlying private-law concept.

## E - Execution

1. Identify the private-law institution: person, act, right, obligation, liability, defense, property, contract, tort, data, or family/succession.
2. Identify legal system and source: PRC Civil Code, common law, civil law, EU/GDPR, contract instrument, or comparative explanation.
3. Decide whether the English candidate is a functional equivalent, partial equivalent, or false friend.
4. Prefer legally anchored phrases over elegant but vague wording.
5. Add a translator note when no exact equivalent exists.
6. Output: recommended term; legal-system condition; rejected alternatives; consistency warning.

## B - Boundary

This skill provides terminology and drafting judgment, not substantive advice on whether a right exists, whether limitation has expired, or whether liability is established. For corporate documents, use `commercial-corporate-finance-translator`; for insurance/maritime risk, use `commercial-instruments-maritime-insurance-translator`.

## Related Skills

- `foreign-legal-english-term-precision`: for general term consistency and role labels.
- `commercial-corporate-finance-translator`: for company and securities concepts built on civil/private law.
- `commercial-instruments-maritime-insurance-translator`: for trade, maritime, and insurance documents.

## Audit

- Distillation: merged civil concepts by shared false-equivalence and legal-system-selection method.
- Quality gates: V1/V2/V3 passed in `../verified.md`.