Afghanistan | Muslim | | based on mixed civil and sharia law |
Albania | Civil law | | has a civil law system |
Algeria | Mixed | Civil law/Muslim | socialist, based on French and Islamic law |
Andorra | Customary | | based on French and Spanish civil codes |
Angola | Civil law | | based on Portuguese civil law system and customary law, modified to accommodate political pluralism and increased use of free markets |
Anguilla | Common law | | based on English common law |
Antigua and Barbuda | Common law | | based on English common law |
Argentina | Civil law | | mixture of US and West European legal systems |
Armenia | Civil law | | based on civil law system |
Aruba | Civil law | | based on Dutch civil law system, with some English common law influence |
Australia | Common law | | based on English common law |
Austria | Civil law | | civil law system with Roman law origin |
Azerbaijan | Civil law | | based on civil law system |
Azores | Civil law | | |
Bahamas, The | Common law | | based on English common law |
Bahrain | Mixed | Muslim/Civil law/Common law/Customary law | based on Islamic law and English common law |
Bangladesh | Mixed | Muslim/Common law | based on English common law |
Barbados | Common law | | English common law |
Belarus | Civil law | | based on civil law system |
Belgium | Civil law | | based on civil law system influenced by English constitutional theory |
Belize | Common law | | English law |
Benin | Civil law | | based on French civil law and customary law |
Bermuda | Common law | | English law |
Bhutan | Mixed | Customary/Common law | based on Indian law and English common law |
Bolivia | Civil law | | based on Spanish law and Napoleonic Code |
Bosnia and Herzegovina | Civil law | | based on civil law system |
Botswana | Mixed | Civil law/Common law | based on Roman-Dutch law and local customary law |
Brazil | Civil law | | based on Roman codes |
British Indian Ocean Territory | Common law | | the laws of the UK, where applicable, apply |
British Territories of Antartica | Common law | | |
Brunei | Mixed | Muslim/Common law/Customary | based on English common law, for Muslims, Islamic sharia law supersedes civil law concerning Muslim marriages and inheritance |
Bulgaria | Civil law | | civil and criminal law based on Roman law |
Burkina Faso | Mixed | Civil law/Customary | based on French civil law system and customary law |
Burundi | Mixed | Civil law/Customary | based on German and Belgian civil codes and customary law |
Cambodia | Civil law | | primarily a civil law mixture of French-influenced codes from the United Nations Transitional Authority in Cambodia (UNTAC) period, royal decrees, and acts of the legislature, with influences of customary law and remnants of communist legal theory, increasing influence of common law |
Cameroon | Mixed | Civil law/Common law/Customary | based on French civil law system, with common law influence |
Canada | Common law | | based on English common law, except in Quebec, where civil law system based on French law prevails |
Cook Islands | Civil law | | based on New Zealand law and English common law |
Cape Verde | Civil law | | based on the legal system of Portugal |
United Kingdom | Common law | | based on common law tradition with early Roman and modern continental influences, has nonbinding judicial review of Acts of Parliament under the Human Rights Act of 1998 |
Central African Republic | Civil law | | based on French law |
Chad | Mixed | Civil law/Customary | based on French civil law system and Chadian customary law |
Chile | Civil law | | based on Code of 1857 derived from Spanish law and subsequent codes influenced by French and Austrian law |
China | Mixed | Civil law/Customary | based on civil law system, derived from Soviet and continental civil code legal principles |
Colombia | Civil law | | based on Spanish law, a new criminal code modeled after US procedures was enacted into law in 2004 and reached full implementation in January 2008 |
Comoros | Mixed | Civil law/Muslim | French and Islamic law in a new consolidated code |
Congo, Republic of the | Mixed | Civil law/Customary | based on French civil law system and customary law |
Congo, Democratic Republic of the | Mixed | Civil law/Customary | civil law based on Belgian law with Napleonic Civil Code influence |
Cook Islands | Common law | | based on New Zealand law and English common law |
Costa Rica | Civil law | | based on Spanish civil law system |
Côte d'Ivoire | Mixed | Civil law/Customary | based on French civil law system and customary law |
Croatia | Civil law | | based on Austro-Hungarian law system with Communist law influences |
Cuba | Civil law | | based on Spanish civil law and influenced by American legal concepts with large elements of Communist legal theory |
Cyprus | Mixed | Common law/Civil law | based on English common law, with civil law modifications |
Czech Republic | Civil law | | civil law system based on Austro-Hungarian codes, legal code modified to bring it in line with Organization on Security and Cooperation in Europe (OSCE) obligations and to expunge Marxist-Leninist legal theory |
Denmark | Civil law | | civil law system |
Djibouti | Mixed | Civil law/Muslim/Customary | based on French civil law system, traditional practices, and Islamic law |
Dominica | Common law | | based on English common law |
Dominican Republic | Civil law | | based on French civil codes |
Timor-Leste | Mixed | Civil law/Muslim/Customary | On 29 March 2009 the president promulgated the Timor-Leste penal code, UN-drafted legal system based on Indonesian law remains in place for civil codes but is to be replaced by civil codes based on Portuguese law, these have passed but have not been promulgated |
Ecuador | Civil law | | based on civil law system |
Egypt | Mixed | Muslim/Civil law | based on Islamic and civil law (particularly Napoleonic codes) |
El Salvador | Civil law | | based on civil and Roman law with traces of common law |
Equatorial Guinea | Mixed | Civil law/Customary | partly based on Spanish civil law and tribal custom |
Eritrea | Mixed | Civil law/Customary/Muslim | primary basis is the Ethiopian legal code of 1957 with revisions, new civil, commercial, and penal codes have not yet been promulgated, government also issues unilateral proclamations setting laws and policies |
Estonia | Civil law | | based on civil law system |
Ethiopia | Mixed | Civil law/Customary | based on civil law, currently transitional mix of national and regional courts |
Faroe Islands | Civil law | | the laws of Denmark, where applicable, apply |
Fiji | Common law | | based on British system |
Finland | Civil law | | civil law system based on Swedish law |
France | Civil law | | civil law system with indigenous concepts |
French Guiana | Civil law | | |
French Polynesia | Civil law | | the laws of France, where applicable, apply |
French Southern and Antarctic Lands | Civil law | | the laws of France, where applicable, apply |
Gabon | Mixed | Civil law/Customary | based on French civil law system and customary law |
Gambia, The | Mixed | Muslim/Common law/Customary | based on a composite of English common law, Islamic law, and customary law |
Georgia | Civil law | | based on civil law system |
Germany | Civil law | | civil law system with indigenous concepts |
Ghana | Mixed | Common law/Customary | based on English common law and customary law |
Gibraltar | Common law | | the laws of the UK, where applicable, apply |
Greece | Civil law | | based on codified Roman law |
Grenada | Common law | | based on English common law |
Greenland | Civil law | | the laws of Denmark, where applicable, apply |
Guadeloupe | Civil law | | |
Guam | Common law | | modeled on US, US federal laws apply |
Guatemala | Civil law | | civil law system |
Guernsey | Customary | | the laws of the UK, where applicable, apply |
Guinea | Mixed | Civil law/Customary | based on French civil law system, customary law, and decree |
Guinea-Bissau | Mixed | Civil law/Customary | based on French civil law |
Guyana | Mixed | Common law/Civil law | based on English common law with certain admixtures of Roman-Dutch law |
Haiti | Civil law | | based on Roman civil law system |
Hawaii (USA) | Common law | | |
Honduras | Civil law | | rooted in Roman and Spanish civil law with increasing influence of English common law, recent judicial reforms include abandoning Napoleonic legal codes in favor of the oral adversarial system |
Hong Kong | Mixed | Common law/Customary | based on English common law |
Hungary | Civil law | | based on the German-Austrian legal system |
Iceland | Civil law | | civil law system based on Danish law |
India | Mixed | Common law/Muslim/Customary | based on English common law |
Indonesia | Mixed | Civil law/Muslim/Customary | based on Roman-Dutch law, substantially modified by indigenous concepts and by new criminal procedures and election codes |
Iran | Mixed | Muslim/Civil law | based on sharia law system |
Iraq | Mixed | Civil law/Muslim | based on European civil and Islamic law under the framework outlined in the Iraqi Constitution |
Ireland | Common law | | based on English common law substantially modified by indigenous concepts |
Israel | Mixed | Civil law/Common law/Jewish/Muslim | mixture of English common law, British Mandate regulations, and, in personal matters, Jewish, Christian, and Muslim legal systems |
Italy | Civil law | | based on civil law system, appeals treated as new trials |
Jamaica | Common law | | based on English common law |
Japan | Mixed | Civil law/Customary | modeled after European civil law systems with English-American influence |
Jersey | Customary | | the laws of the UK, where applicable, apply and local statutes |
Jordan | Mixed | Civil law/Muslim/Customary | based on Islamic law and French codes |
Kazakhstan | Civil law | | based on Islamic law and Roman law |
Kenya | Mixed | Common law/Customary /Muslim | based on Kenyan statutory law, Kenyan and English common law, tribal law, and Islamic law |
Kiribati | Common law | | English common law supplemented by local, customary law |
Korea, North | Mixed | Civil law/Customary | based on Prussian civil law system with Japanese influences and Communist legal theory |
Korea, South | Mixed | Civil law/Customary | combines elements of continental European civil law systems, Anglo-American law, and Chinese classical thought |
Kuwait | Mixed | Muslim/Civil law/Customary | civil law system with Islamic law significant in personal matters |
Kyrgyzstan | Civil law | | based on French and Russian laws |
Laos | Civil law | | based on traditional customs, French legal norms and procedures, and socialist practice |
Latvia | Civil law | | based on civil law system with traces of Socialist legal traditions and practices |
Lebanon | Mixed | Civil law/Muslim | mixture of Ottoman law, canon law, Napoleonic code, and civil law |
Lesotho | Mixed | Common law/Civil law/Customary | based on English common law and Roman-Dutch law |
Liberia | Mixed | Common law/Customary | dual system of statutory law based on Anglo-American common law for the modern sector and customary law based on unwritten tribal practices for indigenous sector |
Libya | Mixed | Muslim/Civil law | based on Italian and French civil law systems and Islamic law, separate religious courts |
Liechtenstein | Civil law | | local civil and penal codes based on civil law system |
Lithuania | Civil law | | based on civil law system |
Louisiana (USA) | Mixed | Civil law/Common law | |
Luxembourg | Civil law | | based on civil law system |
Macau | Civil law | | based on Portuguese civil law system |
Macedonia [FYROM] | Civil law | | based on civil law system |
Madagascar | Mixed | Civil law/Customary | based on French civil law system and traditional Malagasy law |
Madeira | Civil law | | |
Malawi | Mixed | Common law/Customary | based on English common law and customary law |
Malaysia | Mixed | Muslim/Common law/Customary | based on English common law |
Maldives | Muslim | | based on Islamic law with admixtures of English common law primarily in commercial matters |
Mali | Mixed | Civil law/Customary | based on French civil law system and customary law |
Falkland Islands (Islas Malvinas) | Common law | | English common law |
Malta | Mixed | Civil law/Common law | based on English common law and Roman civil law |
Isle of Man | Common law | | the laws of the UK, where applicable, apply and Manx statutes |
Northern Mariana Islands | Common law | | based on US system, except for customs, wages, immigration laws, and taxation |
Marshall Islands | Common law | | based on adapted Trust Territory laws, acts of the legislature, municipal, common, and customary laws |
Martinique | Civil law | | |
Mauritania | Mixed | Muslim/Civil law | a combination of Islamic law and French civil law |
Mauritius | Mixed | Civil law/Common law | based on French civil law system with elements of English common law in certain areas |
Mayotte | Civil law | | the laws of France, where applicable, apply |
Mexico | Civil law | | mixture of US constitutional theory and civil law system |
Micronesia, Federated States of | Mixed | Common law/Customary | based on adapted Trust Territory laws, acts of the legislature, municipal, common, and customary laws |
Moldova | Civil law | | based on civil law system |
Monaco | Civil law | | based on French law |
Mongolia | Mixed | Customary/Civil law | blend of Soviet and German systems that employ "continental" or "civil" code, case-precedent may be used to inform judges, but all decisions must refer to the law as written |
Montserrat | Common law | | English common law and statutory law |
Montenegro | Civil law | | based on civil law system |
Morocco | Mixed | Muslim/Civil law | based on Islamic law and French and Spanish civil law systems |
Mozambique | Mixed | Customary/Civil law | based on Portuguese civil law system and customary law |
Burma | Mixed | Common law/Customary | based on English common law |
Namibia | Mixed | Common law/Civil law | based on Roman-Dutch law and 1990 constitution |
Nauru | Common law | | acts of the Nauru Parliament and British common law |
Nepal | Mixed | Common law/Customary | based on Hindu legal concepts and English common law |
Netherlands | Civil law | | based on civil law system incorporating French penal theory |
Netherlands Antilles | Civil law | | based on Dutch civil law system with some English common law influence |
New Caledonia | Civil law | | based on French civil law, the 1988 Matignon Accords grant substantial autonomy to the islands |
New Zealand | Common law | | based on English law, with special land legislation and land courts for the Maori |
Nicaragua | Civil law | | civil law system |
Niger | Mixed | Civil law/Customary | based on French civil law system and customary law |
Nigeria | Mixed | Common law/Muslim/Customary | based on English common law, Islamic law (in 12 northern states), and traditional law |
Niue | Common law | | English common law |
Norfolk Island | Common law | | based on the laws of Australia, local ordinances and acts, English common law applies in matters not covered by either Australian or Norfolk Island law |
Northern Ireland (uk) | Common law | | |
Norway | Civil law | | mixture of customary law, civil law system, and common law traditions |
Oman | Mixed | Muslim/Customary/Civil law | based on English common law and Islamic law, ultimate appeal to the monarch |
Pakistan | Mixed | Muslim/Common law | based on English common law with provisions to accommodate Pakistan's status as an Islamic state |
Palau | Common law | | based on Trust Territory laws, acts of the legislature, municipal, common, and customary laws |
Palestine | Mixed | Civil law/Muslim | |
Panama | Civil law | | based on civil law system |
Papua New Guinea | Mixed | Customary/Common law | based on English common law |
Paraguay | Civil law | | based on Argentine codes, Roman law, and French codes |
Peru | Civil law | | based on civil law system |
Philippines | Mixed | Common law/Civil law | based on Spanish and Anglo-American law |
Pitcairn Islands | Common law | | local island by-laws |
Poland | Civil law | | based on a mixture of Continental (Napoleonic) civil law and holdover Communist legal theory, changes being gradually introduced as part of broader democratization process |
Puerto Rico | Mixed | Civil law/Common law | based on Spanish civil code and within the US Federal system of justice |
Portugal | Civil law | | based on civil law system, the Constitutional Tribunal reviews the constitutionality of legislation |
Qatar | Mixed | Muslim/Civil law/Common law/Customary | based on Islamic and civil law codes, discretionary system of law controlled by the Amir, although civil codes are being implemented, Islamic law dominates family and personal matters |
Quebec | Mixed | Civil law/Common law | |
Réunion | Civil law | | |
Romania | Civil law | | based on civil law system |
Russia | Civil law | | based on civil law system |
Rwanda | Mixed | Civil law/Customary | based on German and Belgian civil law systems and customary law |
Saint Barthélemy | Civil law | | the laws of France, where applicable, apply |
Saint Helena | Common law | | |
Saint Kitts and Nevis | Common law | | based on English common law |
Saint Lucia | Mixed | Civil law/Common law | based on English common law |
Saint Martin | Civil law | | the laws of France, where applicable, apply |
Saint Pierre and Miquelon | Civil law | | the laws of France, where applicable, apply |
Saint Vincent and the Grenadines | Common law | | based on English common law |
Samoa | Mixed | Common law/Customary | based on English common law and local customs |
American Samoa | Common law | | |
San Marino | Civil law | | based on civil law system with Italian law influences |
Sao Tome and Principe | Mixed | Civil law/Customary | based on Portuguese legal system and customary law |
Saudi Arabia | Muslim | | based on sharia law, several secular codes have been introduced, commercial disputes handled by special committees |
Scotland | Mixed | Civil law/Common law | |
Senegal | Mixed | Civil law/Customary | based on French civil law system |
Serbia | Civil law | | based on civil law system |
Seychelles | Mixed | Common law/Civil law | based on English common law, French civil law, and customary law |
Sierra Leone | Mixed | Common law/Customary | based on English law and customary laws indigenous to local tribes |
Singapore | Mixed | Common law/Muslim | based on English common law |
Slovakia | Civil law | | civil law system based on Austro-Hungarian codes |
Slovenia | Civil law | | based on civil law system |
Solomon Islands | Mixed | Common law/Customary | English common law, which is widely disregarded |
Somalia | Mixed | Muslim/Civil law/Common law/Customary | no national system, a mixture of English common law, Italian law, Islamic sharia, and Somali customary law |
South Africa | Mixed | Civil law/Common law | based on Roman-Dutch law and English common law |
South Georgia and the Islands | Common law | | |
Spain | Civil law | | civil law system, with regional applications |
Sri Lanka | Mixed | Civil law/Common law/Customary | a highly complex mixture of English common law, Roman-Dutch, Kandyan, and Jaffna Tamil law |
Sudan | Mixed | Muslim/Common law | based on English common law and Islamic law, as of 20 January 1991, the now defunct Revolutionary Command Council imposed Islamic law in the northern states, Islamic law applies to all residents of the northern states regardless of their religion |
Suriname | Civil law | | based on Dutch legal system incorporating French penal theory |
Swaziland | Mixed | Civil law/Customary | based on South African Roman-Dutch law in statutory courts and Swazi traditional law and custom in traditional courts |
Sweden | Civil law | | civil law system influenced by customary law |
Switzerland | Civil law | | civil law system influenced by customary law |
Syria | Mixed | Civil law/Muslim | based on a combination of French and Ottoman civil law |
Taiwan | Mixed | Civil law/Customary | based on civil law system |
Tajikistan | Civil law | | based on civil law system |
Tanzania | Mixed | Common law/Customary | based on English common law |
Thailand | Civil law | | based on civil law system with influences of common law |
Togo | Mixed | Civil law/Customary | French-based court system |
Tokelau | Common law | | New Zealand and local statutes |
Tonga | Common law | | based on English common law |
Trinidad and Tobago | Common law | | based on English common law |
Tunisia | Mixed | Civil law/Muslim | based on French civil law system and Islamic law |
Turkey | Civil law | | civil law system derived from various European continental legal systems, note - member of the European Court of Human Rights (ECHR), although Turkey claims limited derogations on the ratified European Convention on Human Rights |
Turkmenistan | Civil law | | based on Soviet civil law system and Islamic law |
Turks and Caicos Islands | Common law | | based on laws of England and Wales with a few adopted from Jamaica and The Bahamas |
Tuvalu | Common law | | English common law supplemented by local customary law |
Uganda | Mixed | Common law/Customary | in 1995, the government restored the legal system to one based on English common law and customary law |
Ukraine | Civil law | | based on civil law system |
United Arab Emirates | Mixed | Muslim/Customary | based on a dual system of sharia and civil courts |
United Kingdom | Common law | | based on common law tradition with early Roman and modern continental influences, has nonbinding judicial review of Acts of Parliament under the Human Rights Act of 1998 |
United States | Common law | | federal court system based on English common law, each state has its own unique legal system, of which all but one (Louisiana, which is still influenced by the Napoleonic Code) is based on English common law, judicial review of legislative acts |
Uruguay | Civil law | | based on Spanish civil law system |
Uzbekistan | Civil law | | based on civil law system |
Vanuatu | Mixed | Civil law/Customary/Common law | unified system being created from former dual French and British systems |
Holy See (Vatican City) | Civil law | | based on Code of Canon Law and revisions to it |
Venezuela | Civil law | | open, adversarial court system |
Vietnam | Civil law | | based on communist legal theory and French civil law system |
Virgin Islands | Common law | | based on US laws |
British Virgin Islands | Common law | | English law |
Wallis and Futuna | Civil law | | the laws of France, where applicable, apply |
Yemen | Mixed | Muslim/Civil law/Common law/Customary | based on Islamic law, Turkish law, English common law, and local tribal customary law |
Zambia | Mixed | Common law/Customary | based on English common law and customary law |
Zimbabwe | Mixed | Civil law/Common law/Customary | mixture of Roman-Dutch and English common law |
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