FIELD LISTING :: LEGAL SYSTEM
This entry provides the description of a country's legal system. A statement on judicial review of legislative acts is also included for a number of countries. The legal systems of nearly all countries are generally modeled upon elements of five main types: civil law (including French law, the Napoleonic Code, Roman law, Roman-Dutch law, and Spanish law); common law (including United State law); customary law; mixed or pluralistic law; and religious law (including Islamic law). An additional type of legal system - international law, which governs the conduct of independent nations in their relationships with one another - is also addressed below. The following list describes these legal systems, the countries or world regions where these systems are enforced, and a brief statement on the origins and major features of each.


Country Comparison to the World

CountryLEGAL SYSTEM
Afghanistan mixed legal system of civil, customary, and Islamic law
Akrotiri laws applicable to the Cypriot population are, as far as possible, the same as the laws of the Republic of Cyprus; note - the Sovereign Base Area Administration has its own court system to deal with civil and criminal matters
Albania civil law system except in the northern rural areas where customary law known as the "Code of Leke" prevails
Algeria mixed legal system of French civil law and Islamic law; judicial review of legislative acts in ad hoc Constitutional Council composed of various public officials including several Supreme Court justices
American Samoa mixed legal system of US common law and customary law
Andorra mixed legal system of civil and customary law with the influence of canon law
Angola civil legal system based on Portuguese civil law; no judicial review of legislation
Anguilla common law based on the English model
Antarctica Antarctica is administered through annual meetings - known as Antarctic Treaty Consultative Meetings - which include consultative member nations, non-consultative member nations, observer organizations, and expert organizations; decisions from these meetings are carried out by these member nations (with respect to their own nationals and operations) in accordance with their own national laws; more generally, access to the Antarctic Treaty area, that is to all areas between 60 and 90 degrees south latitude, is subject to a number of relevant legal instruments and authorization procedures adopted by the states party to the Antarctic Treaty; note - US law, including certain criminal offenses by or against US nationals, such as murder, may apply extraterritorially; some US laws directly apply to Antarctica; for example, the Antarctic Conservation Act, 16 U.S.C. section 2401 et seq., provides civil and criminal penalties for the following activities unless authorized by regulation of statute: the taking of native mammals or birds; the introduction of nonindigenous plants and animals; entry into specially protected areas; the discharge or disposal of pollutants; and the importation into the US of certain items from Antarctica; violation of the Antarctic Conservation Act carries penalties of up to $10,000 in fines and one year in prison; the National Science Foundation and Department of Justice share enforcement responsibilities; Public Law 95-541, the US Antarctic Conservation Act of 1978, as amended in 1996, requires expeditions from the US to Antarctica to notify, in advance, the Office of Oceans, Room 5805, Department of State, Washington, DC 20520, which reports such plans to other nations as required by the Antarctic Treaty; for more information, contact Permit Office, Office of Polar Programs, National Science Foundation, Arlington, Virginia 22230; telephone: (703) 292-8030, or visit its website at www.nsf.gov
Antigua and Barbuda common law based on the English model
Argentina civil law system based on West European legal systems; note - in 2014, Congress passed government-backed reform to the civil code that will go into effect in 2016
Armenia civil law system
Aruba civil law system based on the Dutch civil code
Ashmore and Cartier Islands the laws of the Commonwealth of Australia and the laws of the Northern Territory of Australia, where applicable, apply
Australia common law system based on the English model
Austria civil law system; judicial review of legislative acts by the Constitutional Court
Azerbaijan civil law system
Bahamas, The common law system based on the English model
Bahrain mixed legal system of Islamic law, English common law, Egyptian civil, criminal, and commercial codes; customary law
Bangladesh mixed legal system of mostly English common law and Islamic law
Barbados English common law; no judicial review of legislative acts
Belarus civil law system; note - nearly all major codes (civil, civil procedure, criminal, criminal procedure, family and labor) have been revised and came into force in 1999 or 2000
Belgium civil law system based on the French Civil Code; note - Belgian law continues to be modified in conformance with the legislative norms mandated by the European Union; judicial review of legislative acts
Belize English common law
Benin civil law system modeled largely on the French system and some customary law
Bermuda English common law
Bhutan civil law based on Buddhist religious law
Bolivia civil law system with influences from Roman, Spanish, canon (religious), French, and indigenous law
Bosnia and Herzegovina civil law system; Constitutional Court review of legislative acts
Botswana mixed legal system of civil law influenced by the Roman-Dutch model and also customary and common law
Bouvet Island the laws of Norway, where applicable, apply
Brazil civil law; note - a new civil law code was enacted in 2002 replacing the 1916 code
British Indian Ocean Territory the laws of the UK, where applicable, apply
British Virgin Islands English common law
Brunei mixed legal system based on English common law and Islamic law; note - in May 2014, the first sharia-based penal codes were instituted and apply to Muslims and non-Muslims
Bulgaria civil law
Burkina Faso civil law based on the French model and customary law
Burma mixed legal system of English common law (as introduced in codifications designed for colonial India) and customary law
Burundi mixed legal system of Belgian civil law and customary law
Cabo Verde civil law system of Portugal
Cambodia civil law system (influenced by the UN Transitional Authority in Cambodia) customary law, Communist legal theory, and common law
Cameroon mixed legal system of English common law, French civil law, and customary law
Canada common law system except in Quebec, where civil law based on the French civil code prevails
Cayman Islands English common law and local statutes
Central African Republic civil law system based on the French model
Chad mixed legal system of civil and customary law
Chile civil law system influenced by several West European civil legal systems; judicial review of legislative acts by the Constitutional Tribunal
China civil law influenced by Soviet and continental European civil law systems; legislature retains power to interpret statutes; note - criminal procedure law revised in early 2012
Christmas Island legal system is under the authority of the governor general of Australia and Australian law
Clipperton Island the laws of France apply
Cocos (Keeling) Islands common law based on the Australian model
Colombia civil law system influenced by the Spanish and French civil codes
Comoros mixed legal system of Islamic religious law, the French civil code of 1975, and customary law
Congo, Democratic Republic of the civil legal system based on Belgian version of French civil law
Congo, Republic of the mixed legal system of French civil law and customary law
Cook Islands common law similar to New Zealand common law
Coral Sea Islands the common law legal system of Australia, where applicable, applies
Costa Rica civil law system based on Spanish civil code; judicial review of legislative acts in the Supreme Court
Cote d'Ivoire civil law system based on the French civil code; judicial review of legislation held in the Constitutional Chamber of the Supreme Court
Croatia civil law system influenced by legal heritage of Austria-Hungary; note - Croatian law was fully harmonized with the European Community acquis as of the June 2010 completion of EU accession negotiations
Cuba civil law system based on Spanish civil code
Curacao based on Dutch civil law system with some English common law influence
Cyprus mixed legal system of English common law and civil law with Greek Orthodox religious law influence
Czech Republic new civil code enacted on 2014, replacing civil code of 1964 - based on former Austro-Hungarian civil codes and socialist theory - and reintroducing former Czech legal terminology
Denmark civil law; judicial review of legislative acts
Dhekelia laws applicable to the Cypriot population are, as far as possible, the same as the laws of the Republic of Cyprus; note - the Sovereign Base Area Administration has its own court system to deal with civil and criminal matters
Djibouti mixed legal system based primarily on the French civil code (as it existed in 1997), Islamic religious law (in matters of family law and successions), and customary law
Dominica common law based on the English model
Dominican Republic civil law system based on the French civil code; Criminal Procedures Code modified in 2004 to include important elements of an accusatory system
Ecuador civil law based on the Chilean civil code with modifications; traditional law in indigenous communities
Egypt mixed legal system based on Napoleonic civil and penal law, Islamic religious law, and vestiges of colonial-era laws; judicial review of the constitutionality of laws by the Supreme Constitutional Court
El Salvador civil law system with minor common law influence; judicial review of legislative acts in the Supreme Court
Equatorial Guinea mixed system of civil and customary law
Eritrea mixed legal system of civil, customary, and Islamic religious law
Estonia civil law system
Ethiopia civil law system
European Union unique supranational law system in which, according to an interpretive declaration of member-state governments appended to the Treaty of Lisbon, "the Treaties and the law adopted by the Union on the basis of the Treaties have primacy over the law of Member States" under conditions laid down in the case law of the Court of Justice; key principles of EU law include fundamental rights as guaranteed by the Charter of Fundamental Rights and as resulting from constitutional traditions common to the EU's states; EU law is divided into 'primary' and 'secondary' legislation; the treaties (primary legislation) are the basis for all EU action; secondary legislation - which includes regulations, directives and decisions - are derived from the principles and objectives set out in the treaties
Falkland Islands (Islas Malvinas) English common law and local statutes
Faroe Islands the laws of Denmark, where applicable, apply
Fiji common law system based on the English model
Finland civil law system based on the Swedish model
France civil law; review of administrative but not legislative acts
French Polynesia the laws of France, where applicable, apply
French Southern and Antarctic Lands the laws of France, where applicable, apply
Gabon mixed legal system of French civil law and customary law
Gambia, The mixed legal system of English common law, Islamic law, and customary law
Georgia civil law system
Germany civil law system
Ghana mixed system of English common law and customary law
Gibraltar the laws of the UK, where applicable, apply
Greece civil legal system based on Roman law
Greenland the laws of Denmark apply
Grenada common law based on English model
Guam common law modeled on US system; US federal laws apply
Guatemala civil law system; judicial review of legislative acts
Guernsey customary legal system based on Norman customary law, and includes elements of the French Civil Code and English common law
Guinea-Bissau mixed legal system of civil law (influenced by the early French Civil Code) and customary law
Guinea civil law system based on the French model
Guyana common law system, based on the English model, with some Roman-Dutch civil law influence
Haiti civil law system strongly influenced by Napoleonic Code
Heard Island and McDonald Islands the laws of Australia, where applicable, apply
Holy See (Vatican City) religious legal system based on canon (religious) law
Honduras civil law system
Hong Kong mixed legal system of common law based on the English model and Chinese customary law (in matters of family and land tenure)
Howland Island the laws of the US, where applicable, apply
Hungary civil legal system influenced by the German model
Iceland civil law system influenced by the Danish model
India common law system based on the English model; separate personal law codes apply to Muslims, Christians, and Hindus; judicial review of legislative acts
Indonesia civil law system based on the Roman-Dutch model and influenced by customary law
Iran religious legal system based on secular and Islamic law
Iraq mixed legal system of civil and Islamic law
Ireland common law system based on the English model but substantially modified by customary law; judicial review of legislative acts in Supreme Court
Isle of Man the laws of the UK where applicable apply and include Manx statutes
Israel mixed legal system of English common law, British Mandate regulations, and Jewish, Christian, and Muslim religious laws
Italy civil law system; judicial review of legislation under certain conditions in Constitutional Court
Jamaica common law system based on the English model
Jan Mayen the laws of Norway, where applicable, apply
Japan civil law system based on German model; system also reflects Anglo-American influence and Japanese traditions; judicial review of legislative acts in the Supreme Court
Jarvis Island the laws of the US, where applicable, apply
Jersey the laws of the UK, where applicable, apply; local statutes
Johnston Atoll the laws of the US, where applicable, apply
Jordan mixed legal system of civil law and Islamic religious law; judicial review of legislative acts in a specially provided High Tribunal
Kazakhstan civil law system influenced by Roman-Germanic law and by the theory and practice of the Russian Federation
Kenya mixed legal system of English common law, Islamic law, and customary law; judicial review in a new Supreme Court established pursuant to the new constitution
Kingman Reef the laws of the US, where applicable, apply
Kiribati English common law supplemented by customary law
Korea, North civil law system based on the Prussian model; system influenced by Japanese traditions and Communist legal theory
Korea, South mixed legal system combining European civil law, Anglo-American law, and Chinese classical thought
Kosovo civil law system; note- the European Union Rule of Law Mission (EULEX) retains limited executive powers related to the investigation of such issues as war crimes
Kuwait mixed legal system consisting of English common law, French civil law, and Islamic religious law
Kyrgyzstan civil law system which includes features of French civil law and Russian Federation laws
Laos civil law system similar in form to the French system
Latvia civil law system with traces of socialist legal traditions and practices
Lebanon mixed legal system of civil law based on the French civil code, Ottoman legal tradition, and religious laws covering personal status, marriage, divorce, and other family relations of the Jewish, Islamic, and Christian communities
Lesotho mixed legal system of English common law and Roman-Dutch law; judicial review of legislative acts in High Court and Court of Appeal
Liberia mixed legal system of common law (based on Anglo-American law) and customary law
Libya Libya's post-revolution legal system is in flux and driven by state and non-state entities
Liechtenstein civil law system influenced by Swiss, Austrian, and German law
Lithuania civil law system; legislative acts can be appealed to the constitutional court
Luxembourg civil law system
Macau civil law system based on the Portuguese model
Macedonia civil law system; judicial review of legislative acts
Madagascar civil law system based on the old French civil code and customary law in matters of marriage, family, and obligation
Malawi mixed legal system of English common law and customary law; judicial review of legislative acts in the Supreme Court of Appeal
Malaysia mixed legal system of English common law, Islamic law, and customary law; judicial review of legislative acts in the Supreme Court at request of supreme head of the federation
Maldives Islamic religious legal system with English common law influences, primarily in commercial matters
Mali civil law system based on the French civil law model and influenced by customary law; judicial review of legislative acts in Constitutional Court
Malta mixed legal system of English common law and civil law (based on the Roman and Napoleonic civil codes)
Marshall Islands mixed legal system of US and English common law, customary law, and local statutes
Mauritania mixed legal system of Islamic and French civil law
Mauritius civil legal system based on French civil law with some elements of English common law
Mexico civil law system with US constitutional law influence; judicial review of legislative acts
Micronesia, Federated States of mixed legal system of common and customary law
Midway Islands the laws of the US, where applicable, apply
Moldova civil law system with Germanic law influences; Constitutional Court review of legislative acts
Monaco civil law system influenced by French legal tradition
Mongolia civil law system influenced by Soviet and Romano-Germanic legal systems; constitution ambiguous on judicial review of legislative acts
Montenegro civil law
Montserrat English common law
Morocco mixed legal system of civil law based on French law and Islamic law; judicial review of legislative acts by Supreme Court
Mozambique mixed legal system of Portuguese civil law, and customary law; note - in rural, predominately Muslim villages with no formal legal system, Islamic law may be applied
Namibia mixed legal system of uncodified civil law based on Roman-Dutch law and customary law
Nauru mixed legal system of common law based on the English model and customary law
Navassa Island the laws of the US, where applicable, apply
Nepal English common law and Hindu legal concepts
Netherlands civil law system based on the French system; constitution does not permit judicial review of acts of the States General
New Caledonia civil law system based on French law; note - the 1988 Matignon Accords (signed in the Matignon Hotel) set up a 10-year period of development during which the Kanak community received substantial autonomy but agreed not to raise the independece issue
New Zealand common law system, based on English model, with special legislation and land courts for the Maori
Nicaragua civil law system; Supreme Court may review administrative acts
Nigeria mixed legal system of English common law, Islamic law (in 12 northern states), and traditional law
Niger mixed legal system of civil law (based on French civil law), Islamic law, and customary law
Niue English common law
Norfolk Island English common law and the laws of Australia
Northern Mariana Islands US system applies, except for customs, wages, immigration laws, and taxation
Norway mixed legal system of civil, common, and customary law; Supreme Court can advise on legislative acts
Oman mixed legal system of Anglo-Saxon law and Islamic law
Pakistan common law system with Islamic law influence
Palau mixed legal system of civil, common, and customary law
Palmyra Atoll the laws of the US, where applicable, apply
Panama civil law system; judicial review of legislative acts in the Supreme Court of Justice
Papua New Guinea mixed legal system of English common law and customary law
Paraguay civil law system with influences from Argentine, Spanish, Roman, and French civil law models; judicial review of legislative acts in Supreme Court of Justice
Peru civil law system
Philippines mixed legal system of civil, common, Islamic, and customary law
Pitcairn Islands local island by-laws
Poland civil law system; changes gradually being introduced as part of broader democratization process; limited judicial review of legislative acts, but rulings of the Constitutional Tribunal are final
Portugal civil law system; Constitutional Court review of legislative acts
Puerto Rico civil law system based on the Spanish civil code and within the framework of the US federal system
Qatar mixed legal system of civil law and Islamic law (in family and personal matters)
Romania civil law system
Russia civil law system; judicial review of legislative acts
Rwanda mixed legal system of civil law, based on German and Belgian models, and customary law; judicial review of legislative acts in the Supreme Court
Saint Barthelemy French civil law
Saint Helena, Ascension, and Tristan da Cunha English common law and local statutes
Saint Kitts and Nevis English common law
Saint Lucia English common law
Saint Martin French civil law
Saint Pierre and Miquelon French civil law
Saint Vincent and the Grenadines English common law
Samoa mixed legal system of English common law and customary law; judicial review of legislative acts with respect to fundamental rights of the citizen
San Marino civil law system with Italian civil law influences
Sao Tome and Principe mixed legal system of civil law base on the Portuguese model and customary law
Saudi Arabia Islamic (sharia) legal system with some elements of Egyptian, French, and customary law; note - several secular codes have been introduced; commercial disputes handled by special committees
Senegal civil law system based on French law; judicial review of legislative acts in Constitutional Court
Serbia civil law system
Seychelles mixed legal system of English common law, French civil law, and customary law
Sierra Leone mixed legal system of English common law and customary law
Singapore English common law
Sint Maarten based on Dutch civil law system with some English common law influence
Slovakia civil law system based on Austro-Hungarian codes; note - legal code modified to comply with the obligations of Organization on Security and Cooperation in Europe and to expunge Marxist-Leninist legal system
Slovenia civil law system
Solomon Islands mixed legal system of English common law and customary law
Somalia mixed legal system of civil law, Islamic law, and customary law (referred to as Xeer)
South Africa mixed legal system of Roman-Dutch civil law, English common law, and customary law
South Georgia and South Sandwich Islands the laws of the UK where applicable apply
Spain civil law system with regional variations
Sri Lanka mixed legal system of Roman-Dutch civil law, English common law, and Jaffna Tamil customary law
Sudan mixed legal system of Islamic law and English common law
Suriname civil law system influenced by Dutch civil law; note - the Commissie Nieuw Surinaamse Burgerlijk Wetboek completed drafting a new civil code in February 2009
Svalbard the laws of Norway where applicable apply
Swaziland mixed legal system of civil, common, and customary law
Sweden civil law system influenced by Roman-Germanic law and customary law
Switzerland civil law system; judicial review of legislative acts, except for federal decrees of a general obligatory character
Syria mixed legal system of civil and Islamic law (for family courts)
Taiwan civil law system
Tajikistan civil law system
Tanzania English common law; judicial review of legislative acts limited to matters of interpretation
Thailand civil law system with common law influences
Timor-Leste civil law system based on the Portuguese model; note - penal and civil law codes to replace the Indonesian codes were passed by Parliament and promulgated in 2009 and 2011, respectively
Togo customary law system
Tokelau common law system of New Zealand
Tonga English common law
Trinidad and Tobago English common law; judicial review of legislative acts in the Supreme Court
Tunisia mixed legal system of civil law, based on the French civil code, and Islamic law; some judicial review of legislative acts in the Supreme Court in joint session
Turkey civil law system based on various European legal systems notably the Swiss civil code
Turkmenistan civil law system with Islamic law influences
Turks and Caicos Islands mixed legal system of English common law and civil law
Tuvalu mixed legal system of English common law and local customary law
Uganda mixed legal system of English common law and customary law
Ukraine civil law system; judicial review of legislative acts
United Arab Emirates mixed legal system of Islamic law and civil law
United Kingdom common law system; has nonbinding judicial review of Acts of Parliament under the Human Rights Act of 1998
United States Pacific Island Wildlife Refuges the laws of the US where applicable apply
United States common law system based on English common law at the federal level; state legal systems based on common law except Louisiana, which is based on Napoleonic civil code; judicial review of legislative acts
Uruguay civil law system based on the Spanish civil code
Uzbekistan civil law system
Vanuatu mixed legal system of English common law, French law, and customary law
Venezuela civil law system based on the Spanish civil code
Vietnam civil law system; note - the civil code of 2005 reflects a European-style civil law
Virgin Islands US common law
Wake Island US common law
Wallis and Futuna French civil law
World the legal systems of nearly all countries are generally modeled upon elements of five main types: civil law (including French law, the Napoleonic Code, Roman law, Roman-Dutch law, and Spanish law); common law (including United States law); customary law; mixed or pluralistic law; and religious law (including Islamic law); an additional type of legal system - international law - governs the conduct of independent nations in their relationships with one another
Yemen mixed legal system of Islamic law, Napoleonic law, English common law, and customary law
Zambia mixed legal system of English common law and customary law; judicial review of legislative acts in an ad hoc constitutional council
Zimbabwe mixed legal system of English common law, Roman-Dutch civil law, and customary law