the two system of course,had a common historical origin and both are clearly common law systems.But the status and practice of stare decisis in each is not generally the same. In England,adherence to past judicial precedent is quite rigirous.
For many years the highest court, the house of lords,held itself absolutely bound by it previous decisions, on the famous
reasoning of Lord Halsbury. There may be a current of opinion in the profession that such a judgment was erroneous; but
what is that occasional interference with what is perhaps abstract justice as compared with the inconvenience the disastrous
inconvenience of having each question subject to being reargued and the dealings of mankind rendered doubtful. London
Streets Tramway Company v.London County Council(1898)A.C.375