Legal system
This entry provides descriptions of countries' legal systems, which are modeled on 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, which governs nations' interactions -- is also addressed below.
Civil Law - the most widespread type of legal system in the world, applied in various forms in approximately 150 countries. Also referred to as European continental law, it is derived mainly from the Roman Corpus Juris Civilus (Body of Civil Law), a collection of laws and legal interpretations compiled under the East Roman (Byzantine) Emperor Justinian I between A.D. 528 and 565. The major feature of civil law systems is that the laws are organized into systematic written codes. The sources recognized as authoritative are principally legislation -- especially codifications in constitutions or government statutes -- and secondarily custom.
Common Law - often called "English common law," England and Wales use the system in the UK, and it is also in force in approximately 80 countries with ties to the former British Empire. English common law reflects Biblical influences as well as remnants of legal systems imposed by early conquerors, including the Romans, Anglo-Saxons, and Normans. Some legal scholars attribute the system to King Henry II (r.1154-1189), who established the king's court to replace locally administered laws and made laws "common" to the entire English realm. The foundation of the system is "legal precedent," often referred to as stare decisis ("to stand by things decided"), in which judges must follow the precedent set by earlier court decisions.
Customary Law - as the name implies, this system is based on the customs of a community. It serves as the basis of or has influenced the laws in approximately 40 countries -- mostly in Africa, but some in the Pacific Islands, Europe, and the Near East. Customary law is also referred to as "primitive law," "unwritten law," "indigenous law," and "folk law." The earliest legal systems were customary and usually developed in small agrarian and hunter-gatherer communities. Customary legal systems are seldom written down, regulate social relations, and are agreed upon by community members. If a law is broken, resolution tends to be reconciliatory rather than punitive.
European Union (EU) Law - a variant of international law unique to a subset of European countries. Also known as Community Law or supranational law, the rights of sovereign European nations are limited in relation to one another, with EU law operating in tandem with the 27 member states' legal systems. The European Court of Justice (ECJ), established in 1952 by the Treaty of Paris, has been largely responsible for the development of EU law. Fundamental principles include: subsidiarity - issues are handled by the smallest, lowest, or least centralized competent authority; proportionality - the EU may only act to the extent needed to achieve its objectives; conferral - the EU is a union of member states, and members grant all its authorities; legal certainty - requires that rules be clear and precise; and precautionary principle - if an action or policy might cause severe or irreversible harm to the public or the environment, in the absence of a scientific consensus that harm would not ensue, the burden of proof falls on those who advocate the action.
French Law - a type of codified civil law that is used in France and serves as the basis for or is mixed with other legal systems in approximately 50 countries in North Africa, the Near East, and French territories and dependencies. Prior to the French Revolution (1789-1799), laws in the northern areas of present-day France were mostly local customs based on privileges and exemptions granted by kings and feudal lords, while in the southern areas Roman law predominated. Napoleon Bonaparte introduced what is now called the Napoleonic Code or the Civil Code in the early 1800s; many of these major reforms remain, with extensive amendments, part of France's current legal structure. French law distinguishes between "public law," which relates to government, the French Constitution, public administration, and criminal law, and "private law," which covers issues between private citizens or corporations.
International Law - the body of customary and treaty rules accepted as legally binding by states in their relations with each other. There are three separate disciplines: public international law, which governs the relationship between provinces and international entities and includes treaty law, law of the sea, international criminal law, and international humanitarian law; private international law, which addresses legal jurisdiction; and supranational law, a legal framework of regional agreements. At present, the European Union is the only entity under a supranational legal system. Modern international law developed as European nation-states emerged beginning in the early 16th century. The sources are set out in Article 38-1 of the Statute of the International Court of Justice in the UN Charter.
Islamic Law - the most widespread type of religious law, it is the legal system in over 30 countries, particularly in the Near East but also in Central and South Asia, Africa, and Indonesia. In many countries, Islamic law operates in tandem with a civil law system and is embodied in the sharia, an Arabic word meaning "the right path." Sharia covers all aspects of public and private life and organizes them into five categories: obligatory, recommended, permitted, disliked, and forbidden. The primary sources of sharia law are the Qur'an and the Sunnah. Traditional Sunni Muslims also recognize the consensus of Muhammad's companions and Islamic jurists on certain issues, called ijmas, and various forms of reasoning, including analogy by legal scholars, referred to as qiyas. Shia Muslims reject ijmas and qiyas as sources of sharia law.
Mixed Law - also referred to as pluralistic law, mixed law consists of elements of some or all of the other main types of legal systems. The mixed systems of a number of countries came about when colonial powers overlaid their own legal systems on colonized regions but retained elements of the colonies' existing systems.
Napoleonic Civil Code - a type of civil law, referred to as the Civil Code or Code Civil des Français, that forms part of the French legal system and underpins the legal systems of Bolivia, Egypt, Lebanon, Poland, and the US state of Louisiana. The Civil Code was established under Napoleon Bonaparte, enacted in 1804, and officially designated the Code Napoleon in 1807. This legal system combined the Teutonic civil law tradition of France's northern provinces with the Roman law tradition of the southern and eastern regions. The Civil Code has similarities with the Roman Body of Civil Law (see Civil Law above). As enacted in 1804, the Code addressed personal status, property, and the acquisition of property, with later additions including civil procedures, commercial law, criminal law and procedures, and a penal code.
Religious Law - a legal system that stems from the sacred text of a religious tradition and in most cases professes to cover all aspects of life as part of devotional obligations. Inalterability is implied, because the word of God cannot be amended or legislated, but human elaboration allows for a detailed legal system. The main types of religious law are sharia in Islam, halakha in Judaism, and canon law in some Christian groups. Sharia is the most widespread (see Islamic Law) and is the sole system for some countries, including Iran, the Maldives, and Saudi Arabia. No country is fully governed by halakha, but Jewish people may decide to settle disputes through Jewish courts. Canon law is not considered a divine law because it is viewed as human law inspired by God. Canon law regulates the internal ordering of the Roman Catholic Church, the Eastern Orthodox Church, and the Anglican Communion.
Roman Law - a type of civil law developed in ancient Rome and practiced from the time of the city's founding (traditionally 753 B.C.) until the fall of the Western Empire in the 5th century A.D. Roman law remained the legal system of the Byzantine (Eastern Empire) until the fall of Constantinople in 1453. Preserved fragments of the first legal text, known as the Law of the Twelve Tables, date from the 5th century B.C. and contain specific provisions designed to change prevailing customary law. Later, emperors asserted their authority as the ultimate source of law. The basis for Roman law was the idea that the exact form -- not the intention -- of words or of actions produced legal consequences. A comprehensive code was published in the late sixth century A.D. (see Civil Law). Roman law served as the basis for legal systems developed in a number of continental European countries.
Roman-Dutch Law - a type of civil law based on Roman law as applied in the Netherlands. Roman-Dutch law is the foundation for legal systems in seven African countries, as well as Guyana, Indonesia, and Sri Lanka. It originated in the province of Holland and expanded throughout the Netherlands and was instituted in a number of sub-Saharan African countries during the Dutch colonial period. The Dutch jurist/philosopher Hugo Grotius was the first to attempt to reduce Roman-Dutch civil law into a system in his Jurisprudence of Holland (1620-21), and the Dutch historian/lawyer Simon van Leeuwen coined the term "Roman-Dutch law" in 1652. It replaced by the French Civil Code in 1809.
Spanish Law - a type of civil law that is often referred to as the Spanish Civil Code. It is the present legal system of Spain and the basis of legal systems in 12 countries, mostly in Central and South America. The Spanish Civil Code reflects a complex mixture of customary, Roman, Napoleonic, local, and modern codified law. The Visigoth invaders in the 5th to 7th centuries were the earliest major influence, and the Christian Reconquest of Spain in the 11th through 15th centuries saw the development of customary law, which combined canon (religious) and Roman law. During several centuries of Hapsburg and Bourbon rule, systematic recompilations of the existing national legal system were attempted, but these often conflicted with local and regional customary civil laws. A national civil law system was finally enacted in 1889 as the Spanish Civil Code, which separates public and private law. Public law includes constitutional law, administrative law, criminal law, process law, financial and tax law, and international public law. Private law includes civil law, commercial law, labor law, and international private law.
United States Law - a type of common law and the basis of the US legal system. This system has several layers, which is due in part to the division between federal and state law. The United States was originally founded as a union of 13 colonies that later became the first states. The US Constitution, implemented in 1789, began shifting power away from the states and toward the federal government, though the states today retain substantial legal authority. US law draws from four sources: constitutional law, statutory law, administrative regulations, and case law. Constitutional law is based on the US Constitution and serves as the supreme federal law, with state constitutions governing state law. US statutory law is legislation enacted by the US Congress and is codified in the United States Code. The 50 state legislatures have similar authority to enact state statutes. Administrative law is the authority delegated to federal and state executive agencies. Case law, also referred to as common law, covers areas where constitutional or statutory law is lacking. Case law is a collection of judicial decisions, customs, and general principles that began in England centuries ago, that were adopted in America at the time of the Revolution, and that continue to develop today.
Afghanistan
the Taliban is implementing its own interpretation of Islamic law, which is partially based on the Hanifi school of Islamic jurisprudence and have enforced strict punishments; before the Taliban takeover, Afghanistan had a mixed legal system of civil, customary, and Islamic law
(2021)Akrotiri and Dhekelia
Laws applicable to the Cypriot population are, as far as possible, the same as the laws of the Republic of Cyprus (ROC); however, the SBA Administration has its own court system to deal with civil and criminal matters, its own police force responsible for civil law enforcement, and a Cyprus Joint Police Unit responsible for military law enforcement; SBA Police coordinate closely with ROC police and UN Peacekeeping Forces in Cyprus (UNFICYP); the SBA Police force is composed almost entirely of Greek Cypriots in ROC regions of the SBAs, and Turkish Cypriot officers in the small portion of Dhekelia administered by the Turkish Cypriots
Albania
civil law system except in the northern rural areas where customary law known as the "Code of Leke" is still presentAlgeria
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 justicesAmerican Samoa
mixed legal system of US common law and customary lawAndorra
mixed legal system of civil and customary law with the influence of canon (religious) lawAngola
civil legal system based on Portuguese civil law; no judicial review of legislationAnguilla
common law based on the English modelAntarctica
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, the Antarctic Treaty area and all areas south of 60 degrees south latitude, including all ice shelves and islands, are subject to a number of relevant legal instruments and 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 extraterritoriality; 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 or 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 Ocean and Polar Affairs, Room 2665, Department of State, Washington, DC 20520, which reports such plans to other nations as required by the Antarctic Treaty; for more information, contact antarctica@state.govAntigua and Barbuda
common law based on the English modelArgentina
civil law system based on West European legal systems; note - in mid-2015, Argentina adopted a new civil code, replacing the old one in force since 1871Armenia
civil law systemAruba
civil law system based on the Dutch civil codeAshmore and Cartier Islands
the laws of the Commonwealth of Australia and the laws of the Northern Territory of Australia, where applicable, applyAustralia
common law system based on the English modelAustria
civil law system; judicial review of legislative acts by the Constitutional CourtAzerbaijan
civil law systemBahamas, The
common law system based on the English modelBahrain
mixed legal system of Islamic (sharia) law, English common law, Egyptian civil, criminal, and commercial codes; customary lawBangladesh
common law; since independence, statutory law enacted by the Parliament of Bangladesh has been the primary form of legislation; Bangladeshi law incorporates elements of English common law; Islamic law applies to Bangladeshi Muslims in family and inheritance laws, with Hindu personal law applying to Bangladeshi Hindus and BuddhistsBarbados
English common law; no judicial review of legislative actsBelarus
civil law system; note - nearly all major codes (civil, civil procedure, criminal, criminal procedure, family, and labor) were revised and came into force in 1999 and 2000Belgium
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 actsBelize
English common lawBenin
civil law system modeled largely on the French system and some customary lawBermuda
English common lawBhutan
civil law based on Buddhist religious lawBolivia
civil law system with influences from Roman, Spanish, canon (religious), French, and indigenous lawBosnia and Herzegovina
civil law system; Constitutional Court review of legislative actsBotswana
mixed legal system of civil law influenced by the Roman-Dutch model and also customary and common lawBouvet Island
the laws of Norway apply where applicableBrazil
civil law; note - a new civil law code was enacted in 2002 replacing the 1916 codeBritish Indian Ocean Territory
the laws of the UK apply where applicableBritish Virgin Islands
English common lawBrunei
mixed legal system based on English common law and Islamic law; note - in April 2019, the full sharia penal codes came into force and apply to Muslims and partly to non-Muslims in parallel with present common law codesBulgaria
civil lawBurkina Faso
civil law based on the French model and customary law; in mid-2019, the National Assembly amended the penal codeBurma
mixed legal system of English common law (as introduced in codifications designed for colonial India) and customary lawBurundi
mixed legal system of Belgian civil law and customary lawCabo Verde
civil law system of PortugalCambodia
civil law system (influenced by the UN Transitional Authority in Cambodia) customary law, Communist legal theory, and common lawCameroon
mixed legal system of English common law, French civil law, and customary lawCanada
common law system except in Quebec, where civil law based on the French civil code prevailsCayman Islands
English common law and local statutesCentral African Republic
civil law system based on the French modelChad
mixed legal system of civil and customary lawChile
civil law system influenced by several West European civil legal systems; judicial review of legislative acts by the Constitutional TribunalChina
civil law influenced by Soviet and continental European civil law systems; legislature retains power to interpret statutes; note - on 28 May 2020, the National People's Congress adopted the PRC Civil Code, which codifies personal relations and property relationsChristmas Island
legal system is under the authority of the governor general of Australia and Australian lawClipperton Island
the laws of France applyCocos (Keeling) Islands
common law based on the Australian modelColombia
civil law system influenced by the Spanish and French civil codesComoros
mixed legal system of Islamic religious law, the French civil code of 1975, and customary lawCongo, Democratic Republic of the
civil law system primarily based on Belgian law, but also customary and tribal lawCongo, Republic of the
mixed legal system of French civil law and customary lawCook Islands
common law similar to New Zealand common lawCoral Sea Islands
the common law legal system of Australia applies where applicableCosta Rica
civil law system based on Spanish civil code; judicial review of legislative acts in the Supreme CourtCote d'Ivoire
civil law system based on the French civil code; judicial review of legislation held in the Constitutional Chamber of the Supreme CourtCroatia
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 negotiationsCuba
civil law system based on Spanish civil codeCuracao
based on Dutch civil law
Cyprus
mixed legal system of English common law and civil law with European law supremacyCzechia
new civil code enacted in 2014, replacing civil code of 1964 - based on former Austro-Hungarian civil codes and socialist theory - and reintroducing former Czech legal terminologyDenmark
civil law; judicial review of legislative actsDjibouti
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 lawDominica
common law based on the English modelDominican Republic
civil law system based on the French civil code; Criminal Procedures Code modified in 2004 to include important elements of an accusatory systemEcuador
civil law based on the Chilean civil code with modifications; traditional law in indigenous communitiesEgypt
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 CourtEl Salvador
civil law system with minor common law influence; judicial review of legislative acts in the Supreme CourtEquatorial Guinea
mixed system of civil and customary lawEritrea
mixed legal system of civil, customary, and Islamic religious lawEstonia
civil law systemEswatini
mixed legal system of civil, common, and customary lawEthiopia
civil law systemEuropean Union
unique supranational system of laws 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 jurisprudence include universal rights as guaranteed by the Charter of Fundamental Rights and as resulting from constitutional traditions common to the EU's 27 member states; EU law is divided into 'primary' and 'secondary' legislation; primary legislation is derived from the consolidated versions of the Treaty on European Union and the Treaty on the Functioning of the European Union and are the basis for all EU action; secondary legislation - which includes directives, regulations, and decisions - is derived from the principles and objectives set out in the treatiesFalkland Islands (Islas Malvinas)
English common law and local statutesFaroe Islands
the laws of Denmark apply where applicableFiji
common law system based on the English modelFinland
civil law system based on the Swedish modelFrance
civil law; review of administrative but not legislative actsFrench Polynesia
the laws of France, where applicable, applyFrench Southern and Antarctic Lands
the laws of France, where applicable, applyGabon
mixed legal system of French civil law and customary lawGambia, The
mixed legal system of English common law, Islamic law, and customary lawGeorgia
civil law systemGermany
civil law systemGhana
mixed system of English common law and customary lawGibraltar
the laws of the UK, where applicable, applyGreece
civil legal system based on Roman lawGreenland
the laws of Denmark apply where applicable and Greenlandic law applies to other areasGrenada
common law based on English modelGuam
common law modeled on US system; US federal laws applyGuatemala
civil law system; judicial review of legislative actsGuernsey
customary legal system based on Norman customary law; includes elements of the French civil code and English common lawGuinea
civil law system based on the French modelGuinea-Bissau
mixed legal system of civil law, which incorporated Portuguese law at independence and influenced by Economic Community of West African States (ECOWAS), West African Economic and Monetary Union (UEMOA), African Francophone Public Law, and customary lawGuyana
common law system, based on the English model, with some Roman-Dutch civil law influenceHaiti
civil law system strongly influenced by Napoleonic CodeHeard Island and McDonald Islands
the laws of Australia apply where applicableHoly See (Vatican City)
religious legal system based on canon (religious) lawHonduras
civil law systemHong Kong
mixed legal system of common law based on the English model and Chinese customary law (in matters of family and land tenure); PRC imposition of National Security Law incorporates elements of Chinese civil lawHungary
civil legal system influenced by the German modelIceland
civil law system influenced by the Danish modelIndia
common law system based on the English model; separate personal law codes apply to Muslims, Christians, and Hindus; judicial review of legislative actsIndonesia
civil law system based on the Roman-Dutch model and influenced by customary lawIran
religious legal system based on secular and Islamic lawIraq
mixed legal system of civil and Islamic lawIreland
common law system based on the English model but substantially modified by customary law; judicial review of legislative acts by Supreme CourtIsle of Man
the laws of the UK apply where applicable and include Manx statutesIsrael
mixed legal system of English common law, British Mandate regulations, and Jewish, Christian, and Muslim religious lawsItaly
civil law system; judicial review of legislation under certain conditions in Constitutional CourtJamaica
common law system based on the English modelJan Mayen
the laws of Norway apply where applicableJapan
civil law system based on German model; system also reflects Anglo-American influence and Japanese traditions; judicial review of legislative acts in the Supreme CourtJersey
the laws of the UK apply where applicable; includes local statutesJordan
mixed system developed from codes instituted by the Ottoman Empire (based on French law), British common law, and Islamic lawKazakhstan
civil law system influenced by Roman-Germanic law and by the theory and practice of the Russian FederationKenya
mixed legal system of English common law, Islamic law, and customary law; judicial review in the new Supreme Court established by the new constitutionKiribati
English common law supplemented by customary lawKorea, North
civil law system based on the Prussian model; system influenced by Japanese traditions and Communist legal theoryKorea, South
mixed legal system combining European civil law, Anglo-American law, and Chinese classical thoughtKosovo
civil law system; note - the European Union Rule of Law Mission (EULEX) retained limited executive powers within the Kosovo judiciary for complex cases from 2008 to 2018Kuwait
mixed legal system consisting of English common law, French civil law, and Islamic sharia lawKyrgyzstan
civil law system, which includes features of French civil law and Russian Federation lawsLaos
civil law system similar in form to the French systemLatvia
civil law system with traces of socialist legal traditions and practicesLebanon
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 communitiesLesotho
mixed legal system of English common law and Roman-Dutch law; judicial review of legislative acts in High Court and Court of AppealLiberia
mixed legal system of common law, based on Anglo-American law, and customary lawLibya
Libya's post-revolution legal system is in flux and driven by state and non-state entitiesLiechtenstein
civil law system influenced by Swiss, Austrian, and German lawLithuania
civil law system; legislative acts can be appealed to the Constitutional CourtLuxembourg
civil law systemMacau
civil law system based on the Portuguese modelMadagascar
civil law system based on the old French civil code and customary law in matters of marriage, family, and obligationMalawi
mixed legal system of English common law and customary law; judicial review of legislative acts in the Supreme Court of AppealMalaysia
mixed legal system of English common law, Islamic law (sharia), and customary law; judicial review of legislative acts in the Federal Court at request of supreme head of the federationMaldives
Islamic (sharia) legal system with English common law influences, primarily in commercial mattersMali
civil law system based on the French civil law model and influenced by customary law; judicial review of legislative acts in the Constitutional CourtMalta
mixed legal system of English common law and civil law based on the Roman and Napoleonic civil codes; subject to European Union lawMarshall Islands
mixed legal system of US and English common law, customary law, and local statutesMauritania
mixed legal system of Islamic and French civil lawMauritius
civil legal system based on French civil law with some elements of English common lawMexico
civil law system with US constitutional law influence; judicial review of legislative actsMicronesia, Federated States of
mixed legal system of common and customary lawMoldova
civil law system with Germanic law influences; Constitutional Court review of legislative actsMonaco
civil law system influenced by French legal traditionMongolia
civil law system influenced by Soviet and Romano-Germanic legal systems; constitution ambiguous on judicial review of legislative actsMontenegro
civil lawMontserrat
English common lawMorocco
mixed legal system of civil law based on French civil law and Islamic (sharia) law; judicial review of legislative acts by Constitutional CourtMozambique
mixed legal system of Portuguese civil law and customary lawNamibia
mixed legal system of uncodified civil law based on Roman-Dutch law and customary lawNauru
mixed legal system of common law based on the English model and customary lawNavassa Island
the laws of the US apply where applicableNepal
English common law and Hindu legal concepts; note - new criminal and civil codes came into effect on 17 August 2018Netherlands
civil law system based on the French system; constitution does not permit judicial review of acts of the States GeneralNew Caledonia
civil law system based on French civil lawNew Zealand
common law system, based on English model, with special legislation and land courts for the MaoriNicaragua
civil law system; Supreme Court may review administrative actsNiger
note - following the 26 July 2023 military coup, the National Council for the Safeguard of the Homeland assumed control of all government institutions and rules by decree; formerly, mixed legal system of civil law, based on French civil law, Islamic law, and customary lawNigeria
mixed legal system of English common law, Islamic law (in 12 northern states), and traditional lawNiue
English common lawNorfolk Island
English common law and the laws of AustraliaNorth Macedonia
civil law system; judicial review of legislative actsNorthern Mariana Islands
the laws of the US apply, except for customs and some aspects of taxationNorway
mixed legal system of civil, common, and customary law; Supreme Court can advise on legislative actsOman
mixed legal system of Anglo-Saxon law and Islamic lawPakistan
common law system with Islamic law influencePalau
mixed legal system of civil, common, and customary lawPanama
civil law system; judicial review of legislative acts in the Supreme Court of JusticePapua New Guinea
mixed legal system of English common law and customary lawParaguay
civil law system with influences from Argentine, Spanish, Roman, and French civil law models; judicial review of legislative acts in Supreme Court of JusticePeru
civil law systemPhilippines
mixed legal system of civil, common, Islamic (sharia), and customary lawPitcairn Islands
local island by-lawsPoland
civil law system; judicial review of legislative, administrative, and other governmental acts; constitutional law rulings of the Constitutional Tribunal are finalPortugal
civil law system; Constitutional Court review of legislative actsPuerto Rico
civil law system based on the Spanish civil code and within the framework of the US federal systemQatar
mixed legal system of civil law and Islamic (sharia) law (in family and personal matters)Romania
civil law systemRussia
civil law system; judicial review of legislative actsRwanda
mixed legal system of civil law, based on German and Belgian models, and customary law; judicial review of legislative acts in the Supreme CourtSaint Barthelemy
French civil lawSaint Helena, Ascension, and Tristan da Cunha
English common law and local statutesSaint Kitts and Nevis
English common lawSaint Lucia
English common lawSaint Martin
French civil lawSaint Pierre and Miquelon
French civil lawSaint Vincent and the Grenadines
English common lawSamoa
mixed legal system of English common law and customary law; judicial review of legislative acts with respect to fundamental rights of the citizenSan Marino
civil law system with Italian civil law influencesSao Tome and Principe
mixed legal system of civil law based on the Portuguese model and customary lawSaudi 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 committeesSenegal
civil law system based on French law; judicial review of legislative acts in Constitutional CouncilSerbia
civil law systemSeychelles
mixed legal system of English common law, French civil law, and customary lawSierra Leone
mixed legal system of English common law and customary lawSingapore
English common lawSint Maarten
based on Dutch civil law system with some English common law influence