How did the common-law rule of primogeniture differ from inheritance practices in continental Europe?

The common-law rule of primogeniture—the practice of passing real property undivided to the eldest son—was a defining feature of English common law designed to maintain the integrity of landholdings tied to feudal military duties and social status. This system ensured that estates remained intact rather than being partitioned among multiple heirs, which would have fragmented the land and diluted the power of the aristocracy.123

In contrast, inheritance practices on the European continent generally favored the equal division of property among all children or relatives of equal degree. While unpartitioned inheritance existed in some European regions to preserve agricultural holdings, the broader trend in continental civil-law systems was toward equal distribution. Following the French Revolution, this principle was codified in the Napoleonic Code, which explicitly prevented the reestablishment of primogeniture by guaranteeing each child a minimum share of the estate, thereby prioritizing equitable inheritance over the preservation of singular, undivided family estates.21