Country ranking for field: legal system 1992

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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.

	World	varies by individual country; 182 are parties to the; United Nations International Court of Justice
1	Afghanistan	0
2	Paraguay	based on Argentine codes Roman law and French codes; judicial review of legislative acts in Supreme Court of Justice; does not accept compulsory ICJ jurisdiction
3	Nigeria	based on English common law Islamic law and tribal law
4	Niue	English common law
5	Norfolk Island Act of 1979; Supreme Court	wide legislative and executive responsibility under the
6	North Korea	based on German civil law system with Japanese influences and Communist legal theory; no judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
7	Northern Mariana Islands	based on US system except for customs wages immigration laws and taxation
8	Norway	mixture 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
9	Oman	based on English common law and Islamic law; ultimate appeal to the sultan; has not accepted compulsory ICJ jurisdiction
10	Pakistan's stature as an Islamic state; accepts compulsory ICJ jurisdiction with reservations	based on English common law with provisions to accommodate
11	Panama	based on civil law system; judicial review of legislative acts in the Supreme Court of Justice; accepts compulsory ICJ jurisdiction with reservations
12	Papua New Guinea	based on English common law
13	Peru	based on civil law system; has not accepted compulsory ICJ jurisdiction
14	Nicaragua	civil law system; Supreme Court may review administrative acts
15	Philippines	based on Spanish and Anglo-American law; accepts compulsory ICJ jurisdiction with reservations
16	Pitcairn Islands	local island by-laws
17	Poland	mixture of Continental
18	Portugal	civil law system; the Constitutional Tribunal reviews the constitutionality of legislation; accepts compulsory ICJ jurisdiction with reservations
19	Puerto Rico	based on Spanish civil code
20	Qatar	discretionary system of law controlled by the amir although civil codes are being implemented; Islamic law is significant in personal matters
21	Romania	former mixture of civil law system and Communist legal theory that increasingly reflected Romanian traditions is being revised
22	Russia	based on civil law system; judicial review of legislative acts; does not accept compulsory ICJ jurisdiction
23	Rwanda	based 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
24	Réunion	French law
25	Saint Helena	NA
26	Niger	based on French civil law system and customary law; has not accepted compulsory ICJ jurisdiction
27	New Zealand	based on English law with special land legislation and land courts for Maoris; accepts compulsory ICJ jurisdiction with reservations
28	Saint Lucia	based on English common law
29	Mayotte	French law
30	Macedonia	based on civil law system; judicial review of legislative acts
31	Madagascar	based on French civil law system and traditional Malagasy law; has not accepted compulsory ICJ jurisdiction
32	Malawi	based on English common law and customary law; judicial review of legislative acts in the Supreme Court of Appeal; has not accepted compulsory ICJ jurisdiction
33	Malaysia	based 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
34	Maldives	based on Islamic law with admixtures of English common law primarily in commercial matters; has not accepted compulsory ICJ jurisdiction
35	State; has not accepted compulsory ICJ jurisdiction	based on French civil law system and customary law; judicial review of legislative acts in Constitutional Section of Court of
36	Malta	based on English common law and Roman civil law; has accepted compulsory ICJ jurisdiction with reservations
37	Marshall Islands	based on adapted Trust Territory laws acts of the legislature municipal common and customary laws
38	Martinique	French legal system
39	Mauritania	based on Islamic law
40	Mauritius	based on French civil law system with elements of English common law in certain areas
41	Mexico	mixture of US constitutional theory and civil law system; judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations
42	New Caledonia	the 1988 Matignon Accords grant substantial autonomy to the islands; formerly under French law
43	Moldova	based on civil law system; no judicial review of legislative acts; does not accept compulsory ICJ jurisdiction but accepts many UN and CSCE documents
44	Monaco	based on French law; has not accepted compulsory ICJ jurisdiction
45	Mongolia	blend of Russian Chinese and Turkish systems of law; no constitutional provision for judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
46	Montserrat	English common law and statute law
47	Supreme Court	based on Islamic law and French and Spanish civil law system; judicial review of legislative acts in Constitutional Chamber of
48	Mozambique	based on Portuguese civil law system and customary law
49	Myanmar	martial law in effect throughout most of the country; has not accepted compulsory ICJ jurisdiction
50	Namibia	based on Roman-Dutch law and 1990 constitution
51	Nauru	own Acts of Parliament and British common law
52	Nepal	based on Hindu legal concepts and English common law; has not accepted compulsory ICJ jurisdiction
53	Netherlands Antilles	based on Dutch civil law system with some English common law influence
54	Saint Kitts and Nevis	based on English common law
55	Saint Vincent and the Grenadines	based on English common law
56	Luxembourg	based on civil law system; accepts compulsory ICJ jurisdiction
57	United Arab Emirates	secular codes are being introduced by the UAE Government and in several member shaykhdoms; Islamic law remains influential
58	Togo	French-based court system
59	Tokelau	British and local statutes
60	Tonga	based on English law
61	Trinidad and Tobago	based on English common law; judicial review of legislative acts in the Supreme Court; has not accepted compulsory ICJ jurisdiction
62	Tunisia	based on French civil law system and Islamic law; some judicial review of legislative acts in the Supreme Court in joint session
63	Turkey	derived from various continental legal systems; accepts compulsory ICJ jurisdiction with reservations
64	Turkmenistan	NA
65	Turks and Caicos Islands	based on laws of England and Wales with a small number adopted from Jamaica and The Bahamas
66	U.S. Virgin Islands	based on US
67	Uganda	government plans to restore system based on English common law and customary law and reinstitute a normal judicial system; accepts compulsory ICJ jurisdiction with reservations
68	Ukraine	based on civil law system; no judicial review of legislative acts
69	United Kingdom	common law tradition with early Roman and modern continental influences; no judicial review of Acts of Parliament; accepts compulsory ICJ jurisdiction with reservations
70	The Gambia	based on a composite of English common law Koranic law and customary law; accepts compulsory ICJ jurisdiction with reservations
71	United States	based on English common law; judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations
72	Uruguay	based on Spanish civil law system; accepts compulsory ICJ jurisdiction
73	Uzbekistan	NA
74	British systems	unified system being created from former dual French and
75	Venezuela	based on Napoleonic code; judicial review of legislative acts in Cassation Court only; has not accepted compulsory ICJ jurisdiction
76	Vietnam	based on Communist legal theory and French civil law system
77	Wallis and Futuna	French
78	Western Samoa	based 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
79	Yemen	based on Islamic law Turkish law English common law and local customary law; does not accept compulsory ICJ jurisdiction
80	Zaire	based on Belgian civil law system and tribal law; has not accepted compulsory ICJ jurisdiction
81	Zambia	based on English common law and customary law; judicial review of legislative acts in an ad hoc constitutional council; has not accepted compulsory ICJ jurisdiction
82	The Netherlands	civil law system incorporating French penal theory; judicial review in the Supreme Court of legislation of lower order rather than Acts of the States General; accepts compulsory ICJ jurisdiction with reservations
83	The Bahamas	based on English common law
84	Saint-Pierre and Miquelon	French law
85	South Korea	combines elements of continental European civil law systems Anglo-American law and Chinese classical thought
86	San Marino	based on civil law system with Italian law influences; has not accepted compulsory ICJ jurisdiction
87	Saudi Arabia	based on Islamic law several secular codes have been introduced; commercial disputes handled by special committees; has not accepted compulsory ICJ jurisdiction
88	Senegal	based 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
89	Serbia and Montenegro	based on civil law system
90	Seychelles	based on English common law French civil law and customary law
91	Sierra Leone	based on English law and customary laws indigenous to local tribes; has not accepted compulsory ICJ jurisdiction
92	ICJ jurisdiction	based on English common law; has not accepted compulsory
93	Slovenia	based on civil law system
94	Solomon Islands	common law
95	South Africa	based on Roman-Dutch law and English common law; accepts compulsory ICJ jurisdiction with reservations
96	South Georgia and the South Sandwich Islands	English common law
97	Spain	civil law system with regional applications; does not accept compulsory ICJ jurisdiction
98	February 1991 military coup	based on civil law system with influences of common law; has not accepted compulsory ICJ jurisdiction; martial law in effect since 23
99	Roman-Dutch Muslim Sinhalese and customary law; has not accepted compulsory ICJ jurisdiction	a highly complex mixture of English common law
100	January 1991 the Revolutionary Command Council imposed Islamic law in the six northern states of Al Wusta Al Khartum Ash Shamaliyah Ash Sharqiyah	based on English common law and Islamic law; as of 20
101	Suriname	NA
102	Swaziland	based on South African Roman-Dutch law in statutory courts Swazi traditional law and custom in traditional courts; has not accepted compulsory ICJ jurisdiction
103	Sweden	civil law system influenced by customary law; accepts compulsory ICJ jurisdiction with reservations
104	Switzerland	civil 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
105	Syria	based on Islamic law and civil law system; special religious courts; has not accepted compulsory ICJ jurisdiction
106	São Tomé and Príncipe	based on Portuguese law system and customary law; has not accepted compulsory ICJ jurisdiction
107	Taiwan	based on civil law system; accepts compulsory ICJ jurisdiction with reservations
108	Tajikistan	based on civil law system; no judicial review of legislative acts
109	Tanzania	based on English common law; judicial review of legislative acts limited to matters of interpretation; has not accepted compulsory ICJ jurisdiction
110	Macau	Portuguese civil law system
111	Lithuania	based on civil law system; no judicial review of legislative acts
112	Albania	has not accepted compulsory ICJ jurisdiction
113	Cocos Islands	based upon the laws of Australia and local laws
114	Burkina Faso	based on French civil law system and customary law
115	Burundi	based on German and Belgian civil codes and customary law; has not accepted compulsory ICJ jurisdiction
116	Cameroon	based on French civil law system with common law influence; has not accepted compulsory ICJ jurisdiction
117	Canada	based on English common law except in Quebec where civil law system based on French law prevails; accepts compulsory ICJ jurisdiction with reservations
118	Cayman Islands	British common law and local statutes
119	Central African Republic	based on French law
120	Chad	based on French civil law system and Chadian customary law; has not accepted compulsory ICJ jurisdiction
121	Chile	based 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
122	China	a 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
123	Christmas Island	under the authority of the governor general of Australia
124	Colombia	based on Spanish law; judicial review of legislative acts in the Supreme Court; accepts compulsory ICJ jurisdiction with reservations
125	Brunei	based on Islamic law
126	Comoros	French and Muslim law in a new consolidated code
127	Congo	based on French civil law system and customary law
128	Costa Rica	based on Spanish civil law system; judicial review of legislative acts in the Supreme Court; has not accepted compulsory ICJ jurisdiction
129	Croatia	based on civil law system; judicial/no judicial review of legislative acts; does/does not accept compulsory ICJ jurisdiction
130	Communist legal theory; does not accept compulsory ICJ jurisdiction	based on Spanish and American law with large elements of
131	Cyprus	based on common law with civil law modifications
132	Côte d'Ivoire	based on French civil law system and customary law; judicial review in the Constitutional Chamber of the Supreme Court; has not accepted compulsory ICJ jurisdiction
133	Denmark	civil law system; judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations
134	Djibouti	based on French civil law system traditional practices and Islamic law
135	Dominica	based on English common law
136	Dominican Republic	based on French civil codes
137	Bulgaria	based on civil law system with Soviet law influence; has accepted compulsory ICJ jurisdiction
138	British Virgin Islands	English law
139	Egypt	based on English common law Islamic law and Napoleonic codes; judicial review by Supreme Court and Council of State
140	Azerbaijan	based on civil law system
141	Algeria	socialist 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
142	Andorra	based on French and Spanish civil codes; no judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
143	Angola	based on Portuguese civil law system and customary law; recently modified to accommodate multipartyism and increased use of free markets
144	Anguilla	based on English common law
145	Antigua and Barbuda	based on English common law
146	Argentina	mixture of US and West European legal systems; has not accepted compulsory ICJ jurisdiction
147	Armenia	based on civil law system
148	Aruba	based on Dutch civil law system with some English common law influence
149	Ashmore and Cartier Islands	relevant laws of the Northern Territory of Australia
150	Australia	based on English common law; accepts compulsory ICJ jurisdiction with reservations
151	Austria	civil 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
152	Bahrain	based on Islamic law and English common law
153	Brazil	based on Latin codes; has not accepted compulsory ICJ jurisdiction
154	Bangladesh	based on English common law
155	Barbados	English common law; no judicial review of legislative acts
156	Belarus	based on civil law system
157	Belgium	civil law system influenced by English constitutional theory; judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations
158	Belize	English law
159	Benin	based on French civil law and customary law; has not accepted compulsory ICJ jurisdiction
160	Bermuda	English law
161	Bhutan	based on Indian law and English common law; has not accepted compulsory ICJ jurisdiction
162	Bolivia	based on Spanish law and Code Napoleon; has not accepted compulsory ICJ jurisdiction
163	Bosnia and Herzegovina	based on civil law system
164	Botswana	based on Roman-Dutch law and local customary law; judicial review limited to matters of interpretation; has not accepted compulsory ICJ jurisdiction
165	Ecuador	based on civil law system; has not accepted compulsory ICJ jurisdiction
166	ICJ jurisdiction with reservations	based on civil and Roman law with traces of common law; judicial review of legislative acts in the Supreme Court; accepts compulsory
167	Liechtenstein	local civil and penal codes; accepts compulsory ICJ jurisdiction with reservations
168	Japan	civil law system with English-American influence; judicial review of legislative acts in the Supreme Court; accepts compulsory ICJ jurisdiction with reservations
169	Western model	in process of revision moving toward rule of law based on
170	Iceland	civil law system based on Danish law; does not accept compulsory ICJ jurisdiction
171	India	based on English common law; limited judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations
172	Indonesia	based on Roman-Dutch law substantially modified by indigenous concepts and by new criminal procedures code; has not accepted compulsory ICJ jurisdiction
173	Iran	the Constitution codifies Islamic principles of government
174	Iraq	based on Islamic law in special religious courts civil law system elsewhere; has not accepted compulsory ICJ jurisdiction
175	Ireland	based on English common law substantially modified by indigenous concepts; judicial review of legislative acts in Supreme Court; has not accepted compulsory ICJ jurisdiction
176	Isle of Man	English law and local statute
177	Israel	mixture 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
178	Italy	based on civil law system with ecclesiastical law influence; appeals treated as trials de novo; judicial review under certain conditions in Constitutional Court; has not accepted compulsory ICJ jurisdiction
179	ICJ jurisdiction	based on English common law; has not accepted compulsory
180	Jersey	English law and local statute
181	English common law; accepts ICJ jurisdiction with reservations	rooted in Roman and Spanish civil law; some influence of
182	Jordan	based on Islamic law and French codes; judicial review of legislative acts in a specially provided High Tribunal; has not accepted compulsory ICJ jurisdiction
183	Kazakhstan	NA
184	Kenya	based on English common law tribal law and Islamic law; judicial review in High Court; accepts compulsory ICJ jurisdiction with reservations; constitutional amendment of 1982 making Kenya a de jure one-party state repealed in 1991
185	Kuwait	civil law system with Islamic law significant in personal matters; has not accepted compulsory ICJ jurisdiction
186	Kyrgyzstan	NA
187	Laos	based on civil law system; has not accepted compulsory ICJ jurisdiction
188	Latvia	based on civil law system
189	Lebanon	mixture of Ottoman law canon law Napoleonic code and civil law; no judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
190	Lesotho	based 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
191	Liberia	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
192	Libya	based 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
193	Hong Kong	based on English common law
194	Haiti	based on Roman civil law system; accepts compulsory ICJ jurisdiction
195	Equatorial Guinea	partly based on Spanish civil law and tribal custom
196	Georgia	NA
197	Estonia	based on civil law system; no judicial review of legislative acts
198	Ethiopia	NA
199	Falkland Islands	English common law
200	Faroe Islands	Danish
201	Federated States of Micronesia	based on adapted Trust Territory laws acts of the legislature municipal common and customary laws
202	Fiji	based on British system
203	Finland	civil law system based on Swedish law; Supreme Court may request legislation interpreting or modifying laws; accepts compulsory ICJ jurisdiction with reservations
204	France	civil law system with indigenous concepts; review of administrative but not legislative acts
205	French Guiana	French legal system
206	French Polynesia	based on French system
207	Court; compulsory ICJ jurisdiction not accepted	based on French civil law system and customary law; judicial review of legislative acts in Constitutional Chamber of the Supreme
208	Germany	civil law system with indigenous concepts; judicial review of legislative acts in the Federal Constitutional Court; has not accepted compulsory ICJ jurisdiction
209	Roman-Dutch law; has not accepted compulsory ICJ jurisdiction	based on English common law with certain admixtures of
210	Ghana	based on English common law and customary law; has not accepted compulsory ICJ jurisdiction
211	Gibraltar	English law
212	Greece	based on codified Roman law; judiciary divided into civil criminal and administrative courts
213	Greenland	Danish
214	Grenada	based on English common law
215	Guadeloupe	French legal system
216	Guam	NA
217	Guatemala	civil law system; judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
218	Guernsey	English law and local statute; justice is administered by the Royal Court
219	Guinea-Bissau	NA
220	Guinea	based on French civil law system customary law and decree; legal codes currently being revised; has not accepted compulsory ICJ jurisdiction
221	Zimbabwe	mixture of Roman-Dutch and English common law

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