Country ranking for field: legal system 1995

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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; 186
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	wide legislative and executive responsibility under the Norfolk Island Act of 1979; Supreme Court
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	based on English common law with provisions to accommodate Pakistan's stature as an Islamic state; accepts compulsory ICJ jurisdiction with reservations
11	Palau	based on Trust Territory laws acts of the legislature municipal common and customary laws
12	Panama	based on civil law system; judicial review of legislative acts in the Supreme Court of Justice; accepts compulsory ICJ jurisdiction with reservations
13	Papua New Guinea	based on English common law
14	Peru	based on civil law system; has not accepted compulsory ICJ jurisdiction
15	Nicaragua	civil law system; Supreme Court may review administrative acts
16	Philippines	based on Spanish and Anglo-American law; accepts compulsory ICJ jurisdiction with reservations
17	Pitcairn Islands	local island by-laws
18	Poland	mixture of Continental
19	Portugal	civil law system; the Constitutional Tribunal reviews the constitutionality of legislation; accepts compulsory ICJ jurisdiction with reservations
20	Puerto Rico	based on Spanish civil code
21	Qatar	discretionary system of law controlled by the amir although civil codes are being implemented; Islamic law is significant in personal matters
22	Romania	former mixture of civil law system and Communist legal theory; is now based on the Constitution of France's Fifth Republic
23	Russia	based on civil law system; judicial review of legislative acts
24	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
25	Réunion	French law
26	Saint Helena	NA
27	Saint Kitts and Nevis	based on English common law
28	Niger	based on French civil law system and customary law; has not accepted compulsory ICJ jurisdiction
29	New Zealand	based on English law with special land legislation and land courts for Maoris; accepts compulsory ICJ jurisdiction with reservations
30	Saint Vincent and the Grenadines	based on English common law
31	Mauritius	based on French civil law system with elements of English common law in certain areas
32	Macau	Portuguese civil law system
33	Macedonia	based on civil law system; judicial review of legislative acts
34	Madagascar	based on French civil law system and traditional Malagasy law; has not accepted compulsory ICJ jurisdiction
35	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
36	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
37	Maldives	based on Islamic law with admixtures of English common law primarily in commercial matters; has not accepted compulsory ICJ jurisdiction
38	Mali	based on French civil law system and customary law; judicial review of legislative acts in Constitutional Court
39	Malta	based on English common law and Roman civil law; has accepted compulsory ICJ jurisdiction with reservations
40	Marshall Islands	based on adapted Trust Territory laws acts of the legislature municipal common and customary laws
41	Martinique	French legal system
42	Mauritania	three-tier system:Islamic
43	Mayotte	French law
44	New Caledonia	the 1988 Matignon Accords grant substantial autonomy to the islands; formerly under French law
45	Mexico	mixture of US constitutional theory and civil law system; judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations
46	Moldova	based on civil law system; no judicial review of legislative acts; does not accept compulsory ICJ jurisdiction but accepts many UN and OSCE documents
47	Monaco	based on French law; has not accepted compulsory ICJ jurisdiction
48	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
49	Montserrat	English common law and statute law
50	Morocco	based on Islamic law and French and Spanish civil law system; judicial review of legislative acts in Constitutional Chamber of Supreme Court
51	Mozambique	based on Portuguese civil law system and customary law
52	Myanmar	has not accepted compulsory ICJ jurisdiction
53	Namibia	based on Roman-Dutch law and 1990 constitution
54	Nauru	own Acts of Parliament and British common law
55	Nepal	based on Hindu legal concepts and English common law; has not accepted compulsory ICJ jurisdiction
56	Netherlands Antilles	based on Dutch civil law system with some English common law influence
57	Saint Lucia	based on English common law
58	Saint-Pierre and Miquelon	French law
59	Lithuania	based on civil law system; no judicial review of legislative acts
60	Ukraine	based on civil law system; no judicial review of legislative acts
61	Togo	French-based court system
62	Tokelau	British and local statutes
63	Tonga	based on English law
64	Trinidad and Tobago	based on English common law; judicial review of legislative acts in the Supreme Court; has not accepted compulsory ICJ jurisdiction
65	Tunisia	based on French civil law system and Islamic law; some judicial review of legislative acts in the Supreme Court in joint session
66	Turkey	derived from various continental legal systems; accepts compulsory ICJ jurisdiction with reservations
67	Turkmenistan	based on civil law system
68	Turks and Caicos Islands	based on laws of England and Wales with a small number adopted from Jamaica and The Bahamas
69	Tuvalu	NA
70	U.S. Virgin Islands	based on US
71	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
72	United Arab Emirates	secular codes are being introduced by the UAE Government and in several member emirates; Islamic law remains influential
73	The Gambia	based on a composite of English common law Koranic law and customary law; accepts compulsory ICJ jurisdiction with reservations
74	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
75	United States	based on English common law; judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations
76	Uruguay	based on Spanish civil law system; accepts compulsory ICJ jurisdiction
77	Uzbekistan	evolution of Soviet civil law; still lacks independent judicial system
78	Vanuatu	unified system being created from former dual French and British systems
79	Venezuela	based on Napoleonic code; judicial review of legislative acts in Cassation Court only; has not accepted compulsory ICJ jurisdiction
80	Vietnam	based on Communist legal theory and French civil law system
81	Wallis and Futuna	French legal system
82	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
83	Yemen	based on Islamic law Turkish law English common law and local tribal customary law; does not accept compulsory ICJ jurisdiction
84	Zaire	based on Belgian civil law system and tribal law; has not accepted compulsory ICJ jurisdiction
85	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
86	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
87	The Bahamas	based on English common law
88	San Marino	based on civil law system with Italian law influences; has not accepted compulsory ICJ jurisdiction
89	South Korea	combines elements of continental European civil law systems Anglo-American law and Chinese classical thought
90	Saudi Arabia	based on Islamic law several secular codes have been introduced; commercial disputes handled by special committees; has not accepted compulsory ICJ jurisdiction
91	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
92	Serbia and Montenegro	based on civil law system
93	Seychelles	based on English common law French civil law and customary law
94	Sierra Leone	based on English law and customary laws indigenous to local tribes; has not accepted compulsory ICJ jurisdiction
95	Singapore	based on English common law; has not accepted compulsory ICJ jurisdiction
96	Slovakia	civil law system based on Austro-Hungarian codes; has not accepted compulsory ICJ jurisdiction; legal code modified to comply with the obligations of Organization on Security and Cooperation in Europe
97	Slovenia	based on civil law system
98	Solomon Islands	common law
99	Somalia	NA
100	South Africa	based on Roman-Dutch law and English common law; accepts compulsory ICJ jurisdiction with reservations
101	South Georgia and the South Sandwich Islands	English common law
102	Spain	civil law system with regional applications; does not accept compulsory ICJ jurisdiction
103	Thailand	based on civil law system with influences of common law; has not accepted compulsory ICJ jurisdiction; martial law in effect since 23 February 1991 military coup
104	Sri Lanka	a highly complex mixture of English common law Roman-Dutch Muslim Sinhalese and customary law; has not accepted compulsory ICJ jurisdiction
105	Sudan	based on English common law and Islamic law; as of 20 January 1991 the now defunct Revolutionary Command Council imposed Islamic law in the northern states; the council is still studying criminal provisions under Islamic law; Islamic law applies to all residents of the northern states regardless of their religion; some separate religious courts; accepts compulsory ICJ jurisdiction with reservations
106	Suriname	NA
107	Svalbard	NA
108	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
109	Sweden	civil law system influenced by customary law; accepts compulsory ICJ jurisdiction with reservations
110	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
111	Syria	based on Islamic law and civil law system; special religious courts; has not accepted compulsory ICJ jurisdiction
112	São Tomé and Príncipe	based on Portuguese law system and customary law; has not accepted compulsory ICJ jurisdiction
113	Taiwan	based on civil law system; accepts compulsory ICJ jurisdiction with reservations
114	Tajikistan	based on civil law system; no judicial review of legislative acts
115	Tanzania	based on English common law; judicial review of legislative acts limited to matters of interpretation; has not accepted compulsory ICJ jurisdiction
116	Luxembourg	based on civil law system; accepts compulsory ICJ jurisdiction
117	Liechtenstein	local civil and penal codes; accepts compulsory ICJ jurisdiction with reservations
118	Albania	has not accepted compulsory ICJ jurisdiction
119	Christmas Island	under the authority of the governor general of Australia
120	Burkina Faso	based on French civil law system and customary law
121	Burundi	based on German and Belgian civil codes and customary law; has not accepted compulsory ICJ jurisdiction
122	Cabo Verde	NA
123	Cambodia	currently being defined
124	Cameroon	based on French civil law system with common law influence; has not accepted compulsory ICJ jurisdiction
125	Canada	based on English common law except in Quebec where civil law system based on French law prevails; accepts compulsory ICJ jurisdiction with reservations
126	Cayman Islands	British common law and local statutes
127	Central African Republic	based on French law
128	Chad	based on French civil law system and Chadian customary law; has not accepted compulsory ICJ jurisdiction
129	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
130	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
131	Cocos Islands	based upon the laws of Australia and local laws
132	Brunei	based on Islamic law
133	Colombia	based on Spanish law; a new criminal code modeled after US procedures was enacted in 1992-93; judicial review of executive and legislative acts; accepts compulsory ICJ jurisdiction with reservations
134	Comoros	French and Muslim law in a new consolidated code
135	Congo	based on French civil law system and customary law
136	Cook Islands	NA
137	Costa Rica	based on Spanish civil law system; judicial review of legislative acts in the Supreme Court; has not accepted compulsory ICJ jurisdiction
138	Croatia	based on civil law system
139	Cuba	based on Spanish and American law with large elements of Communist legal theory; does not accept compulsory ICJ jurisdiction
140	Cyprus	based on common law with civil law modifications
141	Czech Republic	civil law system based on Austro-Hungarian codes; has not accepted compulsory ICJ jurisdiction; legal code modified to bring it in line with Organization on Security and Cooperation in Europe
142	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
143	Denmark	civil law system; judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations
144	Djibouti	based on French civil law system traditional practices and Islamic law
145	Bulgaria	based on civil law system with Soviet law influence; has accepted compulsory ICJ jurisdiction
146	British Virgin Islands	English law
147	Dominican Republic	based on French civil codes
148	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
149	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
150	American Samoa	NA
151	Andorra	based on French and Spanish civil codes; no judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
152	Angola	based on Portuguese civil law system and customary law; recently modified to accommodate political pluralism and increased use of free markets
153	Anguilla	based on English common law
154	Antarctica	US law including certain criminal offenses by or against US nationals such as murder may apply to areas not under jurisdiction of other countries	. Some US laws directly apply to Antarctica
155	Antigua and Barbuda	based on English common law
156	Argentina	mixture of US and West European legal systems; has not accepted compulsory ICJ jurisdiction
157	Armenia	based on civil law system
158	Aruba	based on Dutch civil law system with some English common law influence
159	Ashmore and Cartier Islands	relevant laws of the Northern Territory of Australia
160	Australia	based on English common law; accepts compulsory ICJ jurisdiction with reservations
161	Azerbaijan	based on civil law system
162	Brazil	based on Roman codes; has not accepted compulsory ICJ jurisdiction
163	Bahrain	based on Islamic law and English common law
164	Bangladesh	based on English common law
165	Barbados	English common law; no judicial review of legislative acts
166	Belarus	based on civil law system
167	Belgium	civil law system influenced by English constitutional theory; judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations
168	Belize	English law
169	Benin	based on French civil law and customary law; has not accepted compulsory ICJ jurisdiction
170	Bermuda	English law
171	Bhutan	based on Indian law and English common law; has not accepted compulsory ICJ jurisdiction
172	Bolivia	based on Spanish law and Code Napoleon; has not accepted compulsory ICJ jurisdiction
173	Bosnia and Herzegovina	based on civil law system
174	Botswana	based on Roman-Dutch law and local customary law; judicial review limited to matters of interpretation; has not accepted compulsory ICJ jurisdiction
175	Dominica	based on English common law
176	Ecuador	based on civil law system; has not accepted compulsory ICJ jurisdiction
177	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
178	Jamaica	based on English common law; has not accepted compulsory ICJ jurisdiction
179	Hong Kong	based on English common law
180	Hungary	in process of revision moving toward rule of law based on Western model
181	Iceland	civil law system based on Danish law; does not accept compulsory ICJ jurisdiction
182	India	based on English common law; limited judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations
183	Indonesia	based on Roman-Dutch law substantially modified by indigenous concepts and by new criminal procedures code; has not accepted compulsory ICJ jurisdiction
184	Iran	the Constitution codifies Islamic principles of government
185	Iraq	based on Islamic law in special religious courts civil law system elsewhere; has not accepted compulsory ICJ jurisdiction
186	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
187	Isle of Man	English law and local statute
188	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
189	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
190	Japan	modeled after European civil law system with English-American influence; judicial review of legislative acts in the Supreme Court; accepts compulsory ICJ jurisdiction with reservations
191	Holy See	NA
192	Jersey	English law and local statute
193	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
194	Kazakhstan	based on civil law system
195	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
196	Kiribati	NA
197	Kuwait	civil law system with Islamic law significant in personal matters; has not accepted compulsory ICJ jurisdiction
198	Kyrgyzstan	based on civil law system
199	Laos	based on traditional customs French legal norms and procedures and Socialist practice
200	Latvia	based on civil law system
201	Lebanon	mixture of Ottoman law canon law Napoleonic code and civil law; no judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
202	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
203	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
204	Honduras	rooted in Roman and Spanish civil law; some influence of English common law; accepts ICJ jurisdiction with reservations
205	Haiti	based on Roman civil law system; accepts compulsory ICJ jurisdiction
206	Egypt	based on English common law Islamic law and Napoleonic codes; judicial review by Supreme Court and Council of State
207	French Polynesia	based on French system
208	El Salvador	based 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
209	Equatorial Guinea	partly based on Spanish civil law and tribal custom
210	Eritrea	NA
211	Estonia	based on civil law system; no judicial review of legislative acts
212	Ethiopia	NA
213	Falkland Islands	English common law
214	Faroe Islands	Danish
215	Federated States of Micronesia	based on adapted Trust Territory laws acts of the legislature municipal common and customary laws
216	Fiji	based on British system
217	Finland	civil law system based on Swedish law; Supreme Court may request legislation interpreting or modifying laws; accepts compulsory ICJ jurisdiction with reservations
218	France	civil law system with indigenous concepts; review of administrative but not legislative acts
219	French Guiana	French legal system
220	Gabon	based 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
221	Guyana	based on English common law with certain admixtures of Roman-Dutch law; has not accepted compulsory ICJ jurisdiction
222	Georgia	based on civil law system
223	Germany	civil law system with indigenous concepts; judicial review of legislative acts in the Federal Constitutional Court; has not accepted compulsory ICJ jurisdiction
224	Ghana	based on English common law and customary law; has not accepted compulsory ICJ jurisdiction
225	Gibraltar	English law
226	Greece	based on codified Roman law; judiciary divided into civil criminal and administrative courts
227	Grenada	based on English common law
228	Guadeloupe	French legal system
229	Guam	modeled on US; federal laws apply
230	Guatemala	civil law system; judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
231	Guernsey	English law and local statute; justice is administered by the Royal Court
232	Guinea-Bissau	NA
233	Guinea	based on French civil law system customary law and decree; legal codes currently being revised; has not accepted compulsory ICJ jurisdiction
234	Zimbabwe	mixture of Roman-Dutch and English common law

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