It is too much of a generalization to say that the civil law is purely inquisitorial and the common law adversarial. The ancient Roman custom of arbitration has now been adapted in many common-law jurisdictions to a more inquisitorial form. In some mixed civil law systems, such as those in Scotland, Quebec, and Louisiana, while the substantive law is civil in nature and evolution, the procedural codes that have developed over the last few hundred years are based upon the English adversarial system.