Country ranking for field: legal system 1998

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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.

1	Afghanistan	0
2	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
3	Nauru	acts of the Nauru Parliament and British common law
4	Navassa Island	NA
5	Nepal	based on Hindu legal concepts and English common law; has not accepted compulsory ICJ jurisdiction
6	New Caledonia	the 1988 Matignon Accords grant substantial autonomy to the islands; formerly under French law
7	New Zealand	based on English law with special land legislation and land courts for Maoris; accepts compulsory ICJ jurisdiction with reservations
8	Nicaragua	civil law system; Supreme Court may review administrative acts
9	Niger	based on French civil law system and customary law; has not accepted compulsory ICJ jurisdiction
10	Nigeria	based on English common law Islamic law and tribal law
11	Niue	English common law
12	Norfolk Island	based on the laws of Australia local ordinances and acts; English common law applies in matters not covered by either Australian or Norfolk Island law
13	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
14	Northern Mariana Islands	based on US system except for customs wages immigration laws and taxation
15	Oman	based on English common law and Islamic law; ultimate appeal to the sultan; has not accepted compulsory ICJ jurisdiction
16	Myanmar	does not accept compulsory ICJ jurisdiction
17	Palau	based on Trust Territory laws acts of the legislature municipal common and customary laws
18	Palmyra Atoll	NA
19	Panama	based on civil law system; judicial review of legislative acts in the Supreme Court of Justice; accepts compulsory ICJ jurisdiction with reservations
20	Papua New Guinea	based on English common law
21	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
22	Peru	based on civil law system; has not accepted compulsory ICJ jurisdiction
23	Philippines	based on Spanish and Anglo-American law; accepts compulsory ICJ jurisdiction with reservations
24	Pitcairn Islands	local island by-laws
25	Poland	mixture of Continental
26	Portugal	civil law system; the Constitutional Tribunal reviews the constitutionality of legislation; accepts compulsory ICJ jurisdiction with reservations
27	Puerto Rico	based on Spanish civil code
28	Qatar	discretionary system of law controlled by the amir although civil codes are being implemented; Islamic law is significant in personal matters
29	Namibia	based on Roman-Dutch law and 1990 constitution
30	Mozambique	based on Portuguese civil law system and customary law
31	Russia	based on civil law system; judicial review of legislative acts
32	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
33	Kyrgyzstan	based on civil law system
34	Latvia	based on civil law system
35	Lebanon	mixture of Ottoman law canon law Napoleonic code and civil law; no judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
36	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
37	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
38	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
39	Liechtenstein	local civil and penal codes; accepts compulsory ICJ jurisdiction with reservations
40	Lithuania	based on civil law system; no judicial review of legislative acts
41	Luxembourg	based on civil law system; accepts compulsory ICJ jurisdiction
42	Macau	Portuguese civil law system
43	Madagascar	based on French civil law system and traditional Malagasy law; has not accepted compulsory ICJ jurisdiction
44	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
45	Maldives	based on Islamic law with admixtures of English common law primarily in commercial matters; has not accepted compulsory ICJ jurisdiction
46	Morocco	based on Islamic law and French and Spanish civil law system; judicial review of legislative acts in Constitutional Chamber of Supreme Court
47	Mali	based on French civil law system and customary law; judicial review of legislative acts in Constitutional Court
48	Malta	based on English common law and Roman civil law; has accepted compulsory ICJ jurisdiction with reservations
49	Marshall Islands	based on adapted Trust Territory laws acts of the legislature municipal common and customary laws
50	Martinique	French legal system
51	Mauritania	three-tier system:Islamic
52	Mauritius	based on French civil law system with elements of English common law in certain areas
53	Mayotte	French law
54	Mexico	mixture of US constitutional theory and civil law system; judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations
55	Midway Islands	NA
56	Moldova	based on civil law system; Constitutional Court reviews legality of legislative acts and governmental decisions of resolution; it is unclear if Moldova accepts compulsory ICJ jurisdiction but accepts many UN and OSCE documents
57	Monaco	based on French law; has not accepted compulsory ICJ jurisdiction
58	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
59	Montserrat	English common law and statute law
60	Romania	former mixture of civil law system and communist legal theory; is now based on the Constitution of France's Fifth Republic
61	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
62	Kiribati	NA
63	Uganda	in 1995 the government restored the legal system to one based on English common law and customary law and reinstituted a normal judicial system; accepts compulsory ICJ jurisdiction with reservations
64	The Gambia	based on a composite of English common law Koranic law and customary law; accepts compulsory ICJ jurisdiction with reservations
65	The Netherlands	civil law system incorporating French penal theory; constitution does not permit judicial review of acts of the States General; accepts compulsory ICJ jurisdiction with reservations
66	Togo	French-based court system
67	Tokelau	British and local statutes
68	Tonga	based on English law
69	Trinidad and Tobago	based on English common law; judicial review of legislative acts in the Supreme Court; has not accepted compulsory ICJ jurisdiction
70	Tromelin Island	NA
71	Tunisia	based on French civil law system and Islamic law; some judicial review of legislative acts in the Supreme Court in joint session
72	Turkey	derived from various European continental legal systems; accepts compulsory ICJ jurisdiction with reservations
73	Turkmenistan	based on civil law system
74	Turks and Caicos Islands	based on laws of England and Wales with a small number adopted from Jamaica and The Bahamas
75	Tuvalu	NA
76	Ukraine	based on civil law system; judicial review of legislative acts
77	Thailand	based on civil law system with influences of common law; has not accepted compulsory ICJ jurisdiction
78	United Arab Emirates	federal court system introduced in 1971; all emirates except Dubayy
79	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
80	United States	based on English common law; judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations
81	Uruguay	based on Spanish civil law system; accepts compulsory ICJ jurisdiction
82	Uzbekistan	evolution of Soviet civil law; still lacks independent judicial system
83	Vanuatu	unified system being created from former dual French and British systems
84	Venezuela	based on Napoleonic code; judicial review of legislative acts in Cassation Court only; has not accepted compulsory ICJ jurisdiction
85	Vietnam	based on communist legal theory and French civil law system
86	Wake Island	NA
87	Wallis and Futuna	French legal system
88	Yemen	based on Islamic law Turkish law English common law and local tribal customary law; does not accept compulsory ICJ jurisdiction
89	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
90	The Bahamas	based on English common law
91	Tanzania	based on English common law; judicial review of legislative acts limited to matters of interpretation; has not accepted compulsory ICJ jurisdiction
92	Saint Helena	NA
93	Slovenia	based on civil law system
94	Saint Kitts and Nevis	based on English common law
95	Saint Lucia	based on English common law
96	Saint Vincent and the Grenadines	based on English common law
97	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
98	San Marino	based on civil law system with Italian law influences; has not accepted compulsory ICJ jurisdiction
99	Saudi Arabia	based on Islamic law several secular codes have been introduced; commercial disputes handled by special committees; has not accepted compulsory ICJ jurisdiction
100	Senegal	based on French civil law system; judicial review of legislative acts in Constitutional Court; the Council of State audits the government's accounting office; Senegal has not accepted compulsory ICJ jurisdiction
101	Serbia and Montenegro	based on civil law system
102	Seychelles	based on English common law French civil law and customary law
103	Sierra Leone	based on English law and customary laws indigenous to local tribes; has not accepted compulsory ICJ jurisdiction
104	Singapore	based on English common law; has not accepted compulsory ICJ jurisdiction
105	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
106	Solomon Islands	English common law
107	Tajikistan	based on civil law system; no judicial review of legislative acts
108	Somalia	NA
109	South Africa	based on Roman-Dutch law and English common law; accepts compulsory ICJ jurisdiction with reservations
110	South Korea	combines elements of continental European civil law systems Anglo-American law and Chinese classical thought
111	Spain	civil law system with regional applications; does not accept compulsory ICJ jurisdiction
112	Sri Lanka	a highly complex mixture of English common law Roman-Dutch Muslim Sinhalese and customary law; has not accepted compulsory ICJ jurisdiction
113	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; Islamic law applies to all residents of the northern states regardless of their religion; some separate religious courts; accepts compulsory ICJ jurisdiction with reservations
114	Suriname	based on Dutch legal system incorporating French penal theory
115	Svalbard	NA
116	Swaziland	based on South African Roman-Dutch law in statutory courts and Swazi traditional law and custom in traditional courts; has not accepted compulsory ICJ jurisdiction
117	Sweden	civil law system influenced by customary law; accepts compulsory ICJ jurisdiction with reservations
118	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
119	Syria	based on Islamic law and civil law system; special religious courts; has not accepted compulsory ICJ jurisdiction
120	Taiwan	based on civil law system; accepts compulsory ICJ jurisdiction with reservations
121	Kuwait	civil law system with Islamic law significant in personal matters; has not accepted compulsory ICJ jurisdiction
122	Kingman Reef	NA
123	Albania	has not accepted compulsory ICJ jurisdiction
124	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
125	Brunei	based on English common law; for Muslims Islamic Shari'a law supersedes civil law in a number of areas
126	Bulgaria	civil law and criminal law based on Roman law; accepts compulsory ICJ jurisdiction
127	Burkina Faso	based on French civil law system and customary law
128	Burundi	based on German and Belgian civil codes and customary law; does not accept compulsory ICJ jurisdiction
129	Cabo Verde	derived from the legal system of Portugal
130	Cambodia	currently being defined
131	Cameroon	based on French civil law system with common law influence; does not accept compulsory ICJ jurisdiction
132	Canada	based on English common law except in Quebec where civil law system based on French law prevails; accepts compulsory ICJ jurisdiction with reservations
133	Cayman Islands	British common law and local statutes
134	Central African Republic	based on French law
135	Chad	based on French civil law system and Chadian customary law; does not accept compulsory ICJ jurisdiction
136	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; does not accept compulsory ICJ jurisdiction
137	Christmas Island	under the authority of the governor general of Australia and Australian law
138	British Indian Ocean Territory	NA
139	Clipperton Island	NA
140	Cocos Islands	based upon the laws of Australia and local laws
141	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
142	Comoros	French and Muslim law in a new consolidated code
143	Congo	based on French civil law system and customary law
144	Cook Islands	based on New Zealand law and English common law
145	Coral Sea Islands	the laws of Australia where applicable apply
146	Costa Rica	based on Spanish civil law system; judicial review of legislative acts in the Supreme Court; has not accepted compulsory ICJ jurisdiction
147	Croatia	based on civil law system
148	Cuba	based on Spanish and American law with large elements of Communist legal theory; does not accept compulsory ICJ jurisdiction
149	Cyprus	based on common law with civil law modifications
150	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
151	British Virgin Islands	English law
152	Brazil	based on Roman codes; has not accepted compulsory ICJ jurisdiction
153	Democratic Republic of the Congo	based on Belgian civil law system and tribal law; has not accepted compulsory ICJ jurisdiction
154	Austria	civil law system with Roman law origin; judicial review of legislative acts by the Constitutional Court; separate administrative and civil/penal supreme courts; has not accepted compulsory ICJ jurisdiction
155	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
156	American Samoa	NA
157	Andorra	based on French and Spanish civil codes; no judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
158	Angola	based on Portuguese civil law system and customary law; recently modified to accommodate political pluralism and increased use of free markets
159	Anguilla	based on English common law
160	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
161	Antigua and Barbuda	based on English common law
162	Argentina	mixture of US and West European legal systems; has not accepted compulsory ICJ jurisdiction
163	Armenia	based on civil law system
164	Aruba	based on Dutch civil law system with some English common law influence
165	Ashmore and Cartier Islands	relevant laws of the Northern Territory of Australia
166	Australia	based on English common law; accepts compulsory ICJ jurisdiction with reservations
167	Azerbaijan	based on civil law system
168	Bouvet Island	NA
169	Baker Island	NA
170	Bangladesh	based on English common law
171	Barbados	English common law; no judicial review of legislative acts
172	Bassas da India	NA
173	Belarus	based on civil law system
174	Belgium	civil law system influenced by English constitutional theory; judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations
175	Belize	English law
176	Benin	based on French civil law and customary law; has not accepted compulsory ICJ jurisdiction
177	Bermuda	English law
178	Bhutan	based on Indian law and English common law; has not accepted compulsory ICJ jurisdiction
179	Bolivia	based on Spanish law and Napoleonic Code; has not accepted compulsory ICJ jurisdiction
180	Bosnia and Herzegovina	based on civil law system
181	Botswana	based on Roman-Dutch law and local customary law; judicial review limited to matters of interpretation; has not accepted compulsory ICJ jurisdiction
182	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
183	Denmark	civil law system; judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations
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	Iran	the Constitution codifies Islamic principles of government
186	Guinea	based on French civil law system customary law and decree; legal codes currently being revised; has not accepted compulsory ICJ jurisdiction
187	Guyana	based on English common law with certain admixtures of Roman-Dutch law; has not accepted compulsory ICJ jurisdiction
188	Haiti	based on Roman civil law system; accepts compulsory ICJ jurisdiction
189	Heard Island and McDonald Islands	NA
190	Holy See	NA
191	Honduras	rooted in Roman and Spanish civil law; some influence of English common law; accepts ICJ jurisdiction with reservations
192	Hong Kong	based on English common law
193	Howland Island	NA
194	Hungary	in process of revision moving toward rule of law based on Western model
195	Iceland	civil law system based on Danish law; does not accept compulsory ICJ jurisdiction
196	India	based on English common law; limited judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations
197	Indonesia	based on Roman-Dutch law substantially modified by indigenous concepts and by new criminal procedures code; has not accepted compulsory ICJ jurisdiction
198	Iraq	based on Islamic law in special religious courts civil law system elsewhere; has not accepted compulsory ICJ jurisdiction
199	Guernsey	English law and local statute; justice is administered by the Royal Court
200	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
201	Isle of Man	English law and local statute
202	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
203	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
204	Jamaica	based on English common law; has not accepted compulsory ICJ jurisdiction
205	Jan Mayen	NA
206	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
207	Jarvis Island	NA
208	Jersey	English law and local statute
209	Johnston Atoll	NA
210	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
211	Juan de Nova Island	NA
212	Kazakhstan	based on civil law system
213	Guinea-Bissau	NA
214	Guatemala	civil law system; judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
215	Djibouti	based on French civil law system traditional practices and Islamic law
216	Federated States of Micronesia	based on adapted Trust Territory laws acts of the legislature municipal common and customary laws
217	Dominica	based on English common law
218	Dominican Republic	based on French civil codes
219	Ecuador	based on civil law system; has not accepted compulsory ICJ jurisdiction
220	Egypt	based on English common law Islamic law and Napoleonic codes; judicial review by Supreme Court and Council of State
221	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
222	Equatorial Guinea	partly based on Spanish civil law and tribal custom
223	Eritrea	NA
224	Estonia	based on civil law system; no judicial review of legislative acts
225	Ethiopia	NA
226	Europa Island	NA
227	Falkland Islands	English common law
228	Faroe Islands	Danish
229	Fiji	based on British system
230	Guam	modeled on US; US federal laws apply
231	Finland	civil law system based on Swedish law; Supreme Court may request legislation interpreting or modifying laws; accepts compulsory ICJ jurisdiction with reservations
232	France	civil law system with indigenous concepts; review of administrative but not legislative acts
233	French Polynesia	based on French system
234	French Southern and Antarctic Lands	NA
235	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
236	Georgia	based on civil law system
237	Germany	civil law system with indigenous concepts; judicial review of legislative acts in the Federal Constitutional Court; has not accepted compulsory ICJ jurisdiction
238	Ghana	based on English common law and customary law; has not accepted compulsory ICJ jurisdiction
239	Gibraltar	English law
240	Glorioso Islands	NA
241	Greece	based on codified Roman law; judiciary divided into civil criminal and administrative courts
242	Grenada	based on English common law
243	Guadeloupe	French legal system
244	Zimbabwe	mixture of Roman-Dutch and English common law

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