Country ranking for field: legal system 1990

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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.


The WorldWorldvaries among each of the entities; 162 are parties to the United Nations International Court of Justice
1flag of AfghanistanAfghanistan0 
2flag of ParaguayParaguaybased on Argentine codes Roman law and French codes; judicial review of legislative acts in Supreme Court of Justice; does not accept compulsory ICJ jurisdiction 
3flag of NiueNiueEnglish common law 
4flag of Norfolk IslandNorfolk Islandwide legislative and executive responsibility under the Norfolk Island Act of 1979; Supreme Court 
5flag of North KoreaNorth Koreabased on German civil law system with Japanese influences and Communist legal theory; no judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction 
6flag of Northern Mariana IslandsNorthern Mariana IslandsNA 
7flag of NorwayNorwaymixture of customary law civil law system and common law traditions; Supreme Court renders advisory opinions to legislature when asked; accepts compulsory ICJ jurisdiction with reservations 
8flag of OmanOmanbased on English common law and Islamic law; ultimate appeal to the sultan; has not accepted compulsory ICJ jurisdiction 
9flag of PakistanPakistanbased on English common law with provisions to accommodate Pakistan's stature as an Islamic state; accepts compulsory ICJ jurisdiction with reservations 
10flag of PanamaPanamabased on civil law system; judicial review of legislative acts in the Supreme Court of Justice; accepts compulsory ICJ jurisdiction with reservations 
11flag of Papua New GuineaPapua New Guineabased on English common law 
12flag of PeruPerubased on civil law system; has not accepted compulsory ICJ jurisdiction 
13flag of NigerNigerbased on French civil law system and customary law; has not accepted compulsory ICJ jurisdiction 
14flag of PhilippinesPhilippinesbased on Spanish and Anglo-American law; accepts compulsory ICJ jurisdiction with reservations 
15flag of Pitcairn IslandsPitcairn Islandslocal island by-laws 
16flag of PolandPolandmixture of Continental 
17flag of PortugalPortugalcivil law system; the Constitutional Tribunal reviews the constitutionality of legislation; accepts compulsory ICJ jurisdiction with reservations 
18flag of Puerto RicoPuerto Ricobased on English common law 
19flag of QatarQatardiscretionary system of law controlled by the amir although civil codes are being implemented; Islamic law is significant in personal matters 
20flag of RomaniaRomaniaformer mixture of civil law system and Communist legal theory that increasingly reflected Romanian traditions is being revised; Communist regime had not accepted compulsory ICJ jurisdiction; Provisional Council of National Unity will probably accept ICJ jurisdiction 
21flag of RwandaRwandabased on German and Belgian civil law systems and customary law; judicial review of legislative acts in the Supreme Court; has not accepted compulsory ICJ jurisdiction 
22flag of RéunionRéunionFrench law 
23flag of Saint HelenaSaint HelenaNA 
24flag of NigeriaNigeriabased on English common law Islamic and tribal law 
25flag of NicaraguaNicaraguacivil law system; Supreme Court may review administrative acts 
26flag of Saint LuciaSaint Luciabased on English common law 
27flag of MexicoMexicomixture of US constitutional theory and civil law system; judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations 
28flag of MalaysiaMalaysiabased on English common law; judicial review of legislative acts in the Supreme Court at request of supreme head of the federation; has not accepted compulsory ICJ jurisdiction 
29flag of MaldivesMaldivesbased on Islamic law with admixtures of English common law primarily in commercial matters; has not accepted compulsory ICJ jurisdiction 
30flag of MaliMalibased on French civil law system and customary law; judicial review of legislative acts in Constitutional Section of Court of State; has not accepted compulsory ICJ jurisdiction 
31flag of MaltaMaltabased on English common law and Roman civil law; has accepted compulsory ICJ jurisdiction with reservations 
32flag of Marshall IslandsMarshall Islandsbased on adapted Trust Territory laws acts of the legislature municipal common and customary laws 
33flag of MartiniqueMartiniqueFrench legal system 
34flag of MauritaniaMauritaniabased on Islamic law 
35flag of MauritiusMauritiusbased on French civil law system with elements of English common law in certain areas 
36flag of MayotteMayotteFrench law 
37flag of MonacoMonacobased on French law; has not accepted compulsory ICJ jurisdiction 
38flag of New ZealandNew Zealandbased on English law with special land legislation and land courts for Maoris; accepts compulsory ICJ jurisdiction with reservations 
39flag of MongoliaMongoliablend of Russian Chinese and Turkish systems of law; no constitutional provision for judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction 
40flag of MontserratMontserratEnglish common law and statute law 
41flag of MoroccoMoroccobased on Islamic law and French and Spanish civil law system; judicial review of legislative acts in Constitutional Chamber of Supreme Court 
42flag of MozambiqueMozambiquebased on Portuguese civil law system and customary law 
43flag of MyanmarMyanmarmartial law in effect throughout most of the country; has not accepted compulsory ICJ jurisdiction 
44flag of NamibiaNamibiabased on Roman-Dutch law and customary law 
45flag of NauruNauruown Acts of Parliament and British common law 
46flag of NepalNepalbased on Hindu legal concepts and English common law; has not accepted compulsory ICJ jurisdiction 
47flag of Netherlands AntillesNetherlands Antillesbased on Dutch civil law system with some English common law influence 
48flag of New CaledoniaNew Caledoniathe 1988 Matignon Accords grant substantial autonomy to the islands; formerly under French law 
49flag of Saint Kitts and NevisSaint Kitts and Nevisbased on English common law 
50flag of Saint Vincent and the GrenadinesSaint Vincent and the Grenadinesbased on English common law 
51flag of MadagascarMadagascarbased on French civil law system and traditional Malagasy law; has not accepted compulsory ICJ jurisdiction 
52flag of United Arab EmiratesUnited Arab Emiratessecular codes are being introduced by the UAE Government and in several member shaykhdoms; Islamic law remains influential 
53flag of TogoTogoFrench-based court system 
54flag of TokelauTokelauBritish and local statutes 
55flag of TongaTongabased on English law 
56flag of Trinidad and TobagoTrinidad and Tobagobased on English common law; judicial review of legislative acts in the Supreme Court; has not accepted compulsory ICJ jurisdiction 
57flag of TunisiaTunisiabased on French civil law system and Islamic law; some judicial review of legislative acts in the Supreme Court in joint session 
58flag of TurkeyTurkeyderived from various continental legal systems; accepts compulsory ICJ jurisdiction with reservations 
59flag of Turks and Caicos IslandsTurks and Caicos Islandsbased on laws of England and Wales with a small number adopted from Jamaica and The Bahamas 
60flag of U.S. Virgin IslandsU.S. Virgin Islandsbased on US 
61flag of UgandaUgandagovernment plans to restore system based on English common law and customary law and reinstitute a normal judicial system; accepts compulsory ICJ jurisdiction with reservations 
62flag of United KingdomUnited Kingdomcommon law tradition with early Roman and modern continental influences; no judicial review of Acts of Parliament; accepts compulsory ICJ jurisdiction with reservations 
63flag of The GambiaThe Gambiabased on a composite of English common law Koranic law and customary law; accepts compulsory ICJ jurisdiction with reservations 
64flag of United StatesUnited Statesbased on English common law; judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations 
65flag of UruguayUruguaybased on Spanish civil law system; accepts compulsory ICJ jurisdiction 
66flag of VanuatuVanuatuunified system being created from former dual French and British systems 
67flag of VenezuelaVenezuelabased on Napoleonic code; judicial review of legislative acts in Cassation Court only; has not accepted compulsory ICJ jurisdiction 
68flag of VietnamVietnambased on Communist legal theory and French civil law system 
69flag of Wallis and FutunaWallis and FutunaFrench 
70flag of Western SamoaWestern Samoabased on English common law and local customs; judicial review of legislative acts with respect to fundamental rights of the citizen; has not accepted compulsory ICJ jurisdiction 
71flag of YugoslaviaYugoslaviamixture of civil law system and Communist legal theory; has not accepted compulsory ICJ jurisdiction 
72flag of ZaireZairebased on Belgian civil law system and tribal law; has not accepted compulsory ICJ jurisdiction 
73flag of ZambiaZambiabased on English common law and customary law; judicial review of legislative acts in an ad hoc constitutional council; has not accepted compulsory ICJ jurisdiction 
74flag of The NetherlandsThe Netherlandscivil law system incorporating French penal theory; judicial review in the Supreme Court of legislation of lower order rather than Acts of Parliament; accepts compulsory ICJ jurisdiction with reservations 
75flag of The BahamasThe Bahamasbased on English common law 
76flag of Saint-Pierre and MiquelonSaint-Pierre and MiquelonFrench law 
77flag of Soviet UnionSoviet Unioncivil law system as modified by Communist legal theory; no judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction 
78flag of San MarinoSan Marinobased on civil law system with Italian law influences; has not accepted compulsory ICJ jurisdiction 
79flag of Saudi ArabiaSaudi Arabiabased on Islamic law several secular codes have been introduced; commercial disputes handled by special committees; has not accepted compulsory ICJ jurisdiction 
80flag of SenegalSenegalbased on French civil law system; judicial review of legislative acts in Supreme Court which also audits the government's accounting office; has not accepted compulsory ICJ jurisdiction 
81flag of SeychellesSeychellesbased on English common law French civil law and customary law 
82flag of Sierra LeoneSierra Leonebased on English law and customary laws indigenous to local tribes; has not accepted compulsory ICJ jurisdiction 
83flag of SingaporeSingaporebased on English common law; has not accepted compulsory ICJ jurisdiction 
84flag of Solomon IslandsSolomon Islandscommon law 
85flag of South AfricaSouth Africabased on Roman-Dutch law and English common law; accepts compulsory ICJ jurisdiction with reservations 
86flag of South Georgia and the South Sandwich IslandsSouth Georgia and the South Sandwich IslandsEnglish common law 
87flag of South KoreaSouth Koreacombines elements of continental European civil law systems Anglo-American law and Chinese classical thought; has not accepted compulsory ICJ jurisdiction 
88flag of SpainSpaincivil law system with regional applications; does not accept compulsory ICJ jurisdiction 
89flag of ThailandThailandbased on civil law system with influences of common law; has not accepted compulsory ICJ jurisdiction 
90flag of Sri LankaSri Lankaa highly complex mixture of English common law Roman-Dutch Muslim and customary law; has not accepted compulsory ICJ jurisdiction 
91flag of SudanSudanbased on English common law and Islamic law; in September 1983 then President Nimeiri declared the penal code would conform to Islamic law; some separate religious courts; accepts compulsory ICJ jurisdiction with reservations 
92flag of SurinameSurinameNA 
93flag of SwazilandSwazilandbased on South African Roman-Dutch law in statutory courts Swazi traditional law and custom in traditional courts; has not accepted compulsory ICJ jurisdiction 
94flag of SwedenSwedencivil law system influenced by customary law; accepts compulsory ICJ jurisdiction with reservations 
95flag of SwitzerlandSwitzerlandcivil law system influenced by customary law; judicial review of legislative acts except with respect to federal decrees of general obligatory character; accepts compulsory ICJ jurisdiction with reservations 
96flag of SyriaSyriabased on Islamic law and civil law system; special religious courts; has not accepted compulsory ICJ jurisdiction 
97flag of São Tomé and PríncipeSão Tomé and Príncipebased on Portuguese law system and customary law; has not accepted compulsory ICJ jurisdiction 
98flag of TaiwanTaiwanbased on civil law system; accepts compulsory ICJ jurisdiction with reservations 
99flag of TanzaniaTanzaniabased on English common law; judicial review of legislative acts limited to matters of interpretation; has not accepted compulsory ICJ jurisdiction 
100flag of MalawiMalawibased on English common law and customary law; judicial review of legislative acts in the Supreme Court of Appeal; has not accepted compulsory ICJ jurisdiction 
101flag of MacauMacauPortuguese civil law system 
102flag of AlbaniaAlbaniajudicial review of legislative acts only in the Presidium of the People's Assembly which is not a true court; has not accepted compulsory ICJ jurisdiction 
103flag of Cocos IslandsCocos Islandsbased upon the laws of Australia and local laws 
104flag of BurundiBurundibased on German and Belgian civil codes and customary law; has not accepted compulsory ICJ jurisdiction 
105flag of CameroonCameroonbased on French civil law system with common law influence; has not accepted compulsory ICJ jurisdiction 
106flag of CanadaCanadabased on English common law except in Quebec where civil law system based on French law prevails; accepts compulsory ICJ jurisdiction with reservations 
107flag of Cayman IslandsCayman IslandsBritish common law and local statutes 
108flag of Central African RepublicCentral African Republicbased on French law 
109flag of ChadChadbased on French civil law system and Chadian customary law; has not accepted compulsory ICJ jurisdiction 
110flag of ChileChilebased on Code of 1857 derived from Spanish law and subsequent codes influenced by French and Austrian law; judicial review of legislative acts in the Supreme Court; has not accepted compulsory ICJ jurisdiction 
111flag of ChinaChinaa complex amalgam of custom and statute largely criminal law; rudimentary civil code in effect since 1 January 1987; new legal codes in effect since 1 January 1980; continuing efforts are being made to improve civil administrative criminal and commercial law 
112flag of Christmas IslandChristmas Islandunder the authority of the governor general of Australia 
113flag of ColombiaColombiabased on Spanish law; judicial review of legislative acts in the Supreme Court; accepts compulsory ICJ jurisdiction with reservations 
114flag of BulgariaBulgariabased on civil law system with Soviet law influence; judicial review of legislative acts in the State Council; has accepted compulsory ICJ jurisdiction 
115flag of ComorosComorosFrench and Muslim law in a new consolidated code 
116flag of CongoCongobased on French civil law system and customary law 
117flag of Costa RicaCosta Ricabased on Spanish civil law system; judicial review of legislative acts in the Supreme Court; has not accepted compulsory ICJ jurisdiction 
118flag of CubaCubabased on Spanish and American law with large elements of Communist legal theory; does not accept compulsory ICJ jurisdiction 
119flag of CyprusCyprusbased on common law with civil law modifications 
120flag of Côte d'IvoireCôte d'Ivoirebased on French civil law system and customary law; judicial review in the Constitutional Chamber of the Supreme Court; has not accepted compulsory ICJ jurisdiction 
121flag of DenmarkDenmarkcivil law system; judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations 
122flag of DjiboutiDjiboutibased on French civil law system traditional practices and Islamic law 
123flag of DominicaDominicabased on English common law 
124flag of Dominican RepublicDominican Republicbased on French civil codes 
125flag of Burkina FasoBurkina Fasobased on French civil law system and customary law 
126flag of BruneiBruneibased on Islamic law 
127flag of EgyptEgyptbased on English common law Islamic law and Napoleonic codes; judicial review by Supreme Court and Council of State 
128flag of AustriaAustriacivil law system with Roman law origin; judicial review of legislative acts by a Constitutional Court; separate administrative and civil/penal supreme courts; has not accepted compulsory ICJ jurisdiction 
129flag of AlgeriaAlgeriasocialist based on French and Islamic law; judicial review of legislative acts in ad hoc Constitutional Council composed of various public officials including several Supreme Court justices; has not accepted compulsory ICJ jurisdiction 
130flag of AndorraAndorrabased on French and Spanish civil codes; no judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction 
131flag of AngolaAngolabased on Portuguese civil law system and customary law but being modified along socialist lines 
132flag of AnguillaAnguillabased on English common law 
133flag of Antigua and BarbudaAntigua and Barbudabased on English common law 
134flag of ArgentinaArgentinamixture of US and West European legal systems; has not accepted compulsory ICJ jurisdiction 
135flag of ArubaArubabased on Dutch civil law system with some English common law influence 
136flag of Ashmore and Cartier IslandsAshmore and Cartier Islandsrelevant laws of the Northern Territory of Australia 
137flag of AustraliaAustraliabased on English common law; accepts compulsory ICJ jurisdiction with reservations 
138flag of BahrainBahrainbased on Islamic law and English common law 
139flag of British Virgin IslandsBritish Virgin IslandsEnglish law 
140flag of BangladeshBangladeshbased on English common law 
141flag of BarbadosBarbadosEnglish common law; no judicial review of legislative acts 
142flag of BelgiumBelgiumcivil law system influenced by English constitutional theory; judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations 
143flag of BelizeBelizeEnglish law 
144flag of BeninBeninbased on French civil law and customary law; has not accepted compulsory ICJ jurisdiction 
145flag of BermudaBermudaEnglish law 
146flag of BhutanBhutanbased on Indian law and English common law; has not accepted compulsory ICJ jurisdiction 
147flag of BoliviaBoliviabased on Spanish law and Code Napoleon; has not accepted compulsory ICJ jurisdiction 
148flag of BotswanaBotswanabased on Roman-Dutch law and local customary law; judicial review limited to matters of interpretation; has not accepted compulsory ICJ jurisdiction 
149flag of BrazilBrazilbased on Latin codes; has not accepted compulsory ICJ jurisdiction 
150flag of EcuadorEcuadorbased on civil law system; has not accepted compulsory ICJ jurisdiction 
151flag of El SalvadorEl Salvadorbased on civil and Roman law with traces of common law; judicial review of legislative acts in the Supreme Court; accepts compulsory ICJ jurisdiction with reservations 
152flag of LuxembourgLuxembourgbased on civil law system; accepts compulsory ICJ jurisdiction 
153flag of JamaicaJamaicabased on English common law; has not accepted compulsory ICJ jurisdiction 
154flag of IcelandIcelandcivil law system based on Danish law; does not accept compulsory ICJ jurisdiction 
155flag of IndiaIndiabased on English common law; limited judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations 
156flag of IndonesiaIndonesiabased on Roman-Dutch law substantially modified by indigenous concepts and by new criminal procedures code; has not accepted compulsory ICJ jurisdiction 
157flag of IranIranthe new Constitution codifies Islamic principles of government 
158flag of IraqIraqbased on Islamic law in special religious courts civil law system elsewhere; has not accepted compulsory ICJ jurisdiction 
159flag of IrelandIrelandbased on English common law substantially modified by indigenous concepts; judicial review of legislative acts in Supreme Court; has not accepted compulsory ICJ jurisdiction 
160flag of Isle of ManIsle of ManEnglish law and local statute 
161flag of IsraelIsraelmixture of English common law British Mandate regulations and in personal matters Jewish Christian and Muslim legal systems; in December 1985 Israel informed the UN Secretariat that it would no longer accept compulsory ICJ jurisdiction 
162flag of ItalyItalybased on civil law system with ecclesiastical law influence; judicial review under certain conditions in Constitutional Court; has not accepted compulsory ICJ jurisdiction 
163flag of JapanJapancivil law system with English-American influence; judicial review of legislative acts in the Supreme Court; accepts compulsory ICJ jurisdiction with reservations 
164flag of Hong KongHong Kongbased on English common law 
165flag of JerseyJerseyEnglish law and local statute 
166flag of JordanJordanbased on Islamic law and French codes; judicial review of legislative acts in a specially provided High Tribunal; has not accepted compulsory ICJ jurisdiction 
167flag of KenyaKenyabased on English common law tribal law and Islamic law; judicial review in High Court; accepts compulsory ICJ jurisdiction with reservations; constitutional amendment in 1982 made Kenya a de jure one-party state 
168flag of KuwaitKuwaitcivil law system with Islamic law significant in personal matters; has not accepted compulsory ICJ jurisdiction 
169flag of LaosLaosbased on civil law system; has not accepted compulsory ICJ jurisdiction 
170flag of LebanonLebanonmixture of Ottoman law canon law Napoleonic code and civil law; no judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction 
171flag of LesothoLesothobased on English common law and Roman-Dutch law; judicial review of legislative acts in High Court and Court of Appeal; has not accepted compulsory ICJ jurisdiction 
172flag of LiberiaLiberiadual 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 
173flag of LibyaLibyabased on Italian civil law system and Islamic law; separate religious courts; no constitutional provision for judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction 
174flag of LiechtensteinLiechtensteinlocal civil and penal codes; accepts compulsory ICJ jurisdiction with reservations 
175flag of HungaryHungarybased on Communist legal theory with both civil law system 
176flag of HondurasHondurasrooted in Roman and Spanish civil law; some influence of English common law; accepts ICJ jurisdiction with reservations 
177flag of Equatorial GuineaEquatorial Guineain transition; partly based on Spanish civil law and tribal custom 
178flag of GhanaGhanabased on English common law and customary law; has not accepted compulsory ICJ jurisdiction 
179flag of EthiopiaEthiopiacomplex structure with civil Islamic common and customary law influences; has not accepted compulsory ICJ jurisdiction 
180flag of Falkland IslandsFalkland IslandsEnglish common law 
181flag of Faroe IslandsFaroe IslandsDanish 
182flag of Federated States of MicronesiaFederated States of Micronesiabased on adapted Trust Territory laws acts of the legislature municipal common and customary laws 
183flag of FijiFijibased on British system 
184flag of FinlandFinlandcivil law system based on Swedish law; Supreme Court may request legislation interpreting or modifying laws; accepts compulsory ICJ jurisdiction with reservations 
185flag of FranceFrancecivil law system with indigenous concepts; review of administrative but not legislative acts 
186flag of French GuianaFrench GuianaFrench legal system 
187flag of French PolynesiaFrench Polynesiabased on French system 
188flag of GabonGabonbased on French civil law system and customary law; judicial review of legislative acts in Constitutional Chamber of the Supreme Court; compulsory ICJ jurisdiction not accepted 
189flag of GibraltarGibraltarEnglish law 
190flag of HaitiHaitibased on Roman civil law system; accepts compulsory ICJ jurisdiction 
191flag of GreeceGreeceNA 
192flag of GreenlandGreenlandDanish 
193flag of GrenadaGrenadabased on English common law 
194flag of GuadeloupeGuadeloupeFrench legal system 
195flag of GuamGuamNA 
196flag of GuatemalaGuatemalacivil law system; judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction 
197flag of GuernseyGuernseyEnglish law and local statute; justice is administered by the Royal Court 
198flag of Guinea-BissauGuinea-BissauNA 
199flag of GuineaGuineabased on French civil law system customary law and decree; legal codes currently being revised; has not accepted compulsory ICJ jurisdiction 
200flag of GuyanaGuyanabased on English common law with certain admixtures of Roman-Dutch law; has not accepted compulsory ICJ jurisdiction 
201flag of ZimbabweZimbabwemixture of Roman-Dutch and English common law 


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