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Class action

From United States

Procedure and evidence

What it means

A lawsuit brought by one or a few people on behalf of a large group with the same kind of claim, with the result binding all the group's members unless they opt out.

Why it travels badly

Most legal systems limit a judgment to the parties who are before the court. Many have introduced collective actions, but with very different features: who may sue, whether people must opt in or out, and whether damages are available.

How other systems say it

United States

class action (Federal Rule 23)

A representative sues for a class. Members are bound unless they opt out of the class.

Canada and Australia

class proceedings

Similar to the US model, with rules set by provinces in Canada and by the Federal Court Act in Australia.

Brazil

ação civil pública and ação coletiva

Public bodies and associations can sue for the collective interest in consumer, environmental and similar matters.

Germany

Musterfeststellungsklage and Verbandsklage

Qualified associations bring actions that settle common questions, not personal damages claims by a class.

France

action de groupe

A collective action, brought by approved associations, for certain categories of claims, such as consumer cases.

Tip for translators and students

Do not use 'class action' for civil-law collective actions without a note. Most differ from the US model on who sues and whether money is awarded.

See the Legal Dictionary entry →

Related: Standing (locus standi), Punitive damages, Discovery

Updated October 2026. Spotted a mistake? Tell us.

TheLawToKnow Tools’s glossary is an educational overview of the main differences between legal systems. It is not legal advice.