Montesquieu

Sometimes the laws and the reli­gion have ins­ti­tu­ted seve­ral kinds of civil conjunc­tions, and that is the case among the Mohammedans, where there are various orders of wives, whose chil­dren are reco­gni­zed by being born in the home, or by civil contracts, or even by the mother’s sla­very and sub­se­quent recog­ni­tion by the father.

It would be contrary to rea­son for the law to stig­ma­tize in chil­dren what it has appro­ved in the father : all these chil­dren must the­re­fore inhe­rit, unless there is some par­ti­cu­lar rea­son to oppose it, as in Japan, where it is only the chil­dren of the wife given by the empe­ror who inhe­rit. Politics there requi­res that pos­ses­sions given by the empe­ror not be too much sha­red, because they are sub­ject to a ser­vice, as our fiefs once were.1

[In the edition of 1758, Annex 20 is added here.]