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Legal Systems of the World

Legal Systems of the World
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Country nameLegal systemMixed system componentsHistorical roots
AfghanistanMuslimbased on mixed civil and sharia law
AlbaniaCivil lawhas a civil law system
AlgeriaMixedCivil law/Muslimsocialist, based on French and Islamic law
AndorraCustomarybased on French and Spanish civil codes
AngolaCivil lawbased on Portuguese civil law system and customary law, modified to accommodate political pluralism and increased use of free markets
AnguillaCommon lawbased on English common law
Antigua and BarbudaCommon lawbased on English common law
ArgentinaCivil lawmixture of US and West European legal systems
ArmeniaCivil lawbased on civil law system
ArubaCivil lawbased on Dutch civil law system, with some English common law influence
AustraliaCommon lawbased on English common law
AustriaCivil lawcivil law system with Roman law origin
AzerbaijanCivil lawbased on civil law system
AzoresCivil law
Bahamas, TheCommon lawbased on English common law
BahrainMixedMuslim/Civil law/Common law/Customary lawbased on Islamic law and English common law
BangladeshMixedMuslim/Common lawbased on English common law
BarbadosCommon lawEnglish common law
BelarusCivil lawbased on civil law system
BelgiumCivil lawbased on civil law system influenced by English constitutional theory
BelizeCommon lawEnglish law
BeninCivil lawbased on French civil law and customary law
BermudaCommon lawEnglish law
BhutanMixedCustomary/Common lawbased on Indian law and English common law
BoliviaCivil lawbased on Spanish law and Napoleonic Code
Bosnia and HerzegovinaCivil lawbased on civil law system
BotswanaMixedCivil law/Common lawbased on Roman-Dutch law and local customary law
BrazilCivil lawbased on Roman codes
British Indian Ocean TerritoryCommon lawthe laws of the UK, where applicable, apply
British Territories of AntarticaCommon law
BruneiMixedMuslim/Common law/Customarybased on English common law, for Muslims, Islamic sharia law supersedes civil law concerning Muslim marriages and inheritance
BulgariaCivil lawcivil and criminal law based on Roman law
Burkina FasoMixedCivil law/Customarybased on French civil law system and customary law
BurundiMixedCivil law/Customarybased on German and Belgian civil codes and customary law
CambodiaCivil lawprimarily 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
CameroonMixedCivil law/Common law/Customarybased on French civil law system, with common law influence
CanadaCommon lawbased on English common law, except in Quebec, where civil law system based on French law prevails
Cook IslandsCivil lawbased on New Zealand law and English common law
Cape VerdeCivil lawbased on the legal system of Portugal
United KingdomCommon lawbased 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 RepublicCivil lawbased on French law
ChadMixedCivil law/Customarybased on French civil law system and Chadian customary law
ChileCivil lawbased on Code of 1857 derived from Spanish law and subsequent codes influenced by French and Austrian law
ChinaMixedCivil law/Customarybased on civil law system, derived from Soviet and continental civil code legal principles
ColombiaCivil lawbased on Spanish law, a new criminal code modeled after US procedures was enacted into law in 2004 and reached full implementation in January 2008
ComorosMixedCivil law/MuslimFrench and Islamic law in a new consolidated code
Congo, Republic of theMixedCivil law/Customarybased on French civil law system and customary law
Congo, Democratic Republic of theMixedCivil law/Customarycivil law based on Belgian law with Napleonic Civil Code influence
Cook IslandsCommon lawbased on New Zealand law and English common law
Costa RicaCivil lawbased on Spanish civil law system
Côte d'IvoireMixedCivil law/Customarybased on French civil law system and customary law
CroatiaCivil lawbased on Austro-Hungarian law system with Communist law influences
CubaCivil lawbased on Spanish civil law and influenced by American legal concepts with large elements of Communist legal theory
CyprusMixedCommon law/Civil lawbased on English common law, with civil law modifications
Czech RepublicCivil lawcivil 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
DenmarkCivil lawcivil law system
DjiboutiMixedCivil law/Muslim/Customarybased on French civil law system, traditional practices, and Islamic law
DominicaCommon lawbased on English common law
Dominican RepublicCivil lawbased on French civil codes
Timor-LesteMixedCivil law/Muslim/CustomaryOn 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
EcuadorCivil lawbased on civil law system
EgyptMixedMuslim/Civil lawbased on Islamic and civil law (particularly Napoleonic codes)
El SalvadorCivil lawbased on civil and Roman law with traces of common law
Equatorial GuineaMixedCivil law/Customarypartly based on Spanish civil law and tribal custom
EritreaMixedCivil law/Customary/Muslimprimary 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
EstoniaCivil lawbased on civil law system
EthiopiaMixedCivil law/Customarybased on civil law, currently transitional mix of national and regional courts
Faroe IslandsCivil lawthe laws of Denmark, where applicable, apply
FijiCommon lawbased on British system
FinlandCivil lawcivil law system based on Swedish law
FranceCivil lawcivil law system with indigenous concepts
French GuianaCivil law
French PolynesiaCivil lawthe laws of France, where applicable, apply
French Southern and Antarctic LandsCivil lawthe laws of France, where applicable, apply
GabonMixedCivil law/Customarybased on French civil law system and customary law
Gambia, TheMixedMuslim/Common law/Customarybased on a composite of English common law, Islamic law, and customary law
GeorgiaCivil lawbased on civil law system
GermanyCivil lawcivil law system with indigenous concepts
GhanaMixedCommon law/Customarybased on English common law and customary law
GibraltarCommon lawthe laws of the UK, where applicable, apply
GreeceCivil lawbased on codified Roman law
GrenadaCommon lawbased on English common law
GreenlandCivil lawthe laws of Denmark, where applicable, apply
GuadeloupeCivil law
GuamCommon lawmodeled on US, US federal laws apply
GuatemalaCivil lawcivil law system
GuernseyCustomarythe laws of the UK, where applicable, apply
GuineaMixedCivil law/Customarybased on French civil law system, customary law, and decree
Guinea-BissauMixedCivil law/Customarybased on French civil law
GuyanaMixedCommon law/Civil lawbased on English common law with certain admixtures of Roman-Dutch law
HaitiCivil lawbased on Roman civil law system
Hawaii (USA)Common law
HondurasCivil lawrooted 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 KongMixedCommon law/Customarybased on English common law
HungaryCivil lawbased on the German-Austrian legal system
IcelandCivil lawcivil law system based on Danish law
IndiaMixedCommon law/Muslim/Customarybased on English common law
IndonesiaMixedCivil law/Muslim/Customarybased on Roman-Dutch law, substantially modified by indigenous concepts and by new criminal procedures and election codes
IranMixedMuslim/Civil lawbased on sharia law system
IraqMixedCivil law/Muslim based on European civil and Islamic law under the framework outlined in the Iraqi Constitution
IrelandCommon lawbased on English common law substantially modified by indigenous concepts
IsraelMixedCivil law/Common law/Jewish/Muslimmixture of English common law, British Mandate regulations, and, in personal matters, Jewish, Christian, and Muslim legal systems
ItalyCivil lawbased on civil law system, appeals treated as new trials
JamaicaCommon lawbased on English common law
JapanMixedCivil law/Customarymodeled after European civil law systems with English-American influence
JerseyCustomarythe laws of the UK, where applicable, apply and local statutes
JordanMixedCivil law/Muslim/Customarybased on Islamic law and French codes
KazakhstanCivil lawbased on Islamic law and Roman law
KenyaMixedCommon law/Customary /Muslimbased on Kenyan statutory law, Kenyan and English common law, tribal law, and Islamic law
KiribatiCommon lawEnglish common law supplemented by local, customary law
Korea, NorthMixedCivil law/Customarybased on Prussian civil law system with Japanese influences and Communist legal theory
Korea, SouthMixedCivil law/Customarycombines elements of continental European civil law systems, Anglo-American law, and Chinese classical thought
KuwaitMixedMuslim/Civil law/Customarycivil law system with Islamic law significant in personal matters
KyrgyzstanCivil lawbased on French and Russian laws
LaosCivil lawbased on traditional customs, French legal norms and procedures, and socialist practice
LatviaCivil lawbased on civil law system with traces of Socialist legal traditions and practices
LebanonMixedCivil law/Muslimmixture of Ottoman law, canon law, Napoleonic code, and civil law
LesothoMixedCommon law/Civil law/Customarybased on English common law and Roman-Dutch law
LiberiaMixedCommon 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
LibyaMixedMuslim/Civil lawbased on Italian and French civil law systems and Islamic law, separate religious courts
LiechtensteinCivil lawlocal civil and penal codes based on civil law system
LithuaniaCivil lawbased on civil law system
Louisiana (USA)MixedCivil law/Common law
LuxembourgCivil lawbased on civil law system
MacauCivil lawbased on Portuguese civil law system
Macedonia [FYROM]Civil lawbased on civil law system
MadagascarMixedCivil law/Customarybased on French civil law system and traditional Malagasy law
MadeiraCivil law
MalawiMixedCommon law/Customarybased on English common law and customary law
MalaysiaMixedMuslim/Common law/Customarybased on English common law
MaldivesMuslimbased on Islamic law with admixtures of English common law primarily in commercial matters
MaliMixedCivil law/Customarybased on French civil law system and customary law
Falkland Islands (Islas Malvinas)Common lawEnglish common law
MaltaMixedCivil law/Common lawbased on English common law and Roman civil law
Isle of ManCommon lawthe laws of the UK, where applicable, apply and Manx statutes
Northern Mariana IslandsCommon lawbased on US system, except for customs, wages, immigration laws, and taxation
Marshall IslandsCommon lawbased on adapted Trust Territory laws, acts of the legislature, municipal, common, and customary laws
MartiniqueCivil law
MauritaniaMixedMuslim/Civil lawa combination of Islamic law and French civil law
MauritiusMixedCivil law/Common lawbased on French civil law system with elements of English common law in certain areas
MayotteCivil lawthe laws of France, where applicable, apply
MexicoCivil lawmixture of US constitutional theory and civil law system
Micronesia, Federated States ofMixedCommon law/Customarybased on adapted Trust Territory laws, acts of the legislature, municipal, common, and customary laws
MoldovaCivil lawbased on civil law system
MonacoCivil lawbased on French law
MongoliaMixedCustomary/Civil lawblend 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
MontserratCommon lawEnglish common law and statutory law
MontenegroCivil lawbased on civil law system
MoroccoMixedMuslim/Civil lawbased on Islamic law and French and Spanish civil law systems
MozambiqueMixedCustomary/Civil lawbased on Portuguese civil law system and customary law
BurmaMixedCommon law/Customarybased on English common law
NamibiaMixedCommon law/Civil lawbased on Roman-Dutch law and 1990 constitution
NauruCommon lawacts of the Nauru Parliament and British common law
NepalMixedCommon law/Customarybased on Hindu legal concepts and English common law
NetherlandsCivil lawbased on civil law system incorporating French penal theory
Netherlands AntillesCivil lawbased on Dutch civil law system with some English common law influence
New CaledoniaCivil lawbased on French civil law, the 1988 Matignon Accords grant substantial autonomy to the islands
New ZealandCommon lawbased on English law, with special land legislation and land courts for the Maori
NicaraguaCivil lawcivil law system
NigerMixedCivil law/Customarybased on French civil law system and customary law
NigeriaMixedCommon law/Muslim/Customarybased on English common law, Islamic law (in 12 northern states), and traditional law
NiueCommon lawEnglish common law
Norfolk IslandCommon lawbased 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
NorwayCivil lawmixture of customary law, civil law system, and common law traditions
OmanMixedMuslim/Customary/Civil lawbased on English common law and Islamic law, ultimate appeal to the monarch
PakistanMixedMuslim/Common lawbased on English common law with provisions to accommodate Pakistan's status as an Islamic state
PalauCommon lawbased on Trust Territory laws, acts of the legislature, municipal, common, and customary laws
PalestineMixedCivil law/Muslim
PanamaCivil lawbased on civil law system
Papua New GuineaMixedCustomary/Common lawbased on English common law
ParaguayCivil lawbased on Argentine codes, Roman law, and French codes
PeruCivil lawbased on civil law system
PhilippinesMixedCommon law/Civil lawbased on Spanish and Anglo-American law
Pitcairn IslandsCommon lawlocal island by-laws
PolandCivil lawbased on a mixture of Continental (Napoleonic) civil law and holdover Communist legal theory, changes being gradually introduced as part of broader democratization process
Puerto RicoMixedCivil law/Common lawbased on Spanish civil code and within the US Federal system of justice
PortugalCivil lawbased on civil law system, the Constitutional Tribunal reviews the constitutionality of legislation
QatarMixedMuslim/Civil law/Common law/Customarybased 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
QuebecMixedCivil law/Common law
RéunionCivil law
RomaniaCivil lawbased on civil law system
RussiaCivil lawbased on civil law system
RwandaMixedCivil law/Customarybased on German and Belgian civil law systems and customary law
Saint BarthélemyCivil lawthe laws of France, where applicable, apply
Saint HelenaCommon law
Saint Kitts and NevisCommon lawbased on English common law
Saint LuciaMixedCivil law/Common lawbased on English common law
Saint MartinCivil lawthe laws of France, where applicable, apply
Saint Pierre and MiquelonCivil lawthe laws of France, where applicable, apply
Saint Vincent and the GrenadinesCommon lawbased on English common law
SamoaMixedCommon law/Customarybased on English common law and local customs
American SamoaCommon law
San MarinoCivil lawbased on civil law system with Italian law influences
Sao Tome and PrincipeMixedCivil law/Customarybased on Portuguese legal system and customary law
Saudi ArabiaMuslimbased on sharia law, several secular codes have been introduced, commercial disputes handled by special committees
ScotlandMixedCivil law/Common law
SenegalMixedCivil law/Customarybased on French civil law system
SerbiaCivil lawbased on civil law system
SeychellesMixedCommon law/Civil lawbased on English common law, French civil law, and customary law
Sierra LeoneMixedCommon law/Customarybased on English law and customary laws indigenous to local tribes
SingaporeMixedCommon law/Muslimbased on English common law
SlovakiaCivil lawcivil law system based on Austro-Hungarian codes
SloveniaCivil lawbased on civil law system
Solomon IslandsMixedCommon law/CustomaryEnglish common law, which is widely disregarded
SomaliaMixedMuslim/Civil law/Common law/Customaryno national system, a mixture of English common law, Italian law, Islamic sharia, and Somali customary law
South AfricaMixedCivil law/Common lawbased on Roman-Dutch law and English common law
South Georgia and the IslandsCommon law
SpainCivil lawcivil law system, with regional applications
Sri LankaMixedCivil law/Common law/Customarya highly complex mixture of English common law, Roman-Dutch, Kandyan, and Jaffna Tamil law
SudanMixedMuslim/Common lawbased 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
SurinameCivil lawbased on Dutch legal system incorporating French penal theory
SwazilandMixedCivil law/Customarybased on South African Roman-Dutch law in statutory courts and Swazi traditional law and custom in traditional courts
SwedenCivil lawcivil law system influenced by customary law
SwitzerlandCivil lawcivil law system influenced by customary law
SyriaMixedCivil law/Muslimbased on a combination of French and Ottoman civil law
TaiwanMixedCivil law/Customarybased on civil law system
TajikistanCivil lawbased on civil law system
TanzaniaMixedCommon law/Customarybased on English common law
ThailandCivil lawbased on civil law system with influences of common law
TogoMixedCivil law/CustomaryFrench-based court system
TokelauCommon lawNew Zealand and local statutes
TongaCommon lawbased on English common law
Trinidad and TobagoCommon lawbased on English common law
TunisiaMixedCivil law/Muslimbased on French civil law system and Islamic law
TurkeyCivil lawcivil 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
TurkmenistanCivil lawbased on Soviet civil law system and Islamic law
Turks and Caicos IslandsCommon lawbased on laws of England and Wales with a few adopted from Jamaica and The Bahamas
TuvaluCommon lawEnglish common law supplemented by local customary law
UgandaMixedCommon law/Customaryin 1995, the government restored the legal system to one based on English common law and customary law
UkraineCivil lawbased on civil law system
United Arab EmiratesMixedMuslim/Customarybased on a dual system of sharia and civil courts
United KingdomCommon lawbased 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 StatesCommon lawfederal 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
UruguayCivil lawbased on Spanish civil law system
UzbekistanCivil lawbased on civil law system
VanuatuMixedCivil law/Customary/Common lawunified system being created from former dual French and British systems
Holy See (Vatican City)Civil lawbased on Code of Canon Law and revisions to it
VenezuelaCivil lawopen, adversarial court system
VietnamCivil lawbased on communist legal theory and French civil law system
Virgin IslandsCommon lawbased on US laws
British Virgin IslandsCommon lawEnglish law
Wallis and FutunaCivil lawthe laws of France, where applicable, apply
YemenMixedMuslim/Civil law/Common law/Customarybased on Islamic law, Turkish law, English common law, and local tribal customary law
ZambiaMixedCommon law/Customarybased on English common law and customary law
ZimbabweMixedCivil law/Common law/Customarymixture of Roman-Dutch and English common law
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