Country ranking for field: legal system 1999

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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	all members of the UN
1	Afghanistan	0
2	Oman	based on English common law and Islamic law; ultimate appeal to the monarch; has not accepted compulsory ICJ jurisdiction
3	Nepal	based on Hindu legal concepts and English common law; has not accepted compulsory ICJ jurisdiction
4	Netherlands Antilles	based on Dutch civil law system with some English common law influence
5	New Caledonia	the 1988 Matignon Accords grant substantial autonomy to the islands; formerly under French law
6	New Zealand	based on English law with special land legislation and land courts for Maoris; accepts compulsory ICJ jurisdiction with reservations
7	Nicaragua	civil law system; Supreme Court may review administrative acts
8	Niger	based on French civil law system and customary law; has not accepted compulsory ICJ jurisdiction
9	Nigeria	based on English common law Islamic law and tribal law
10	Niue	English common law
11	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
12	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
13	Northern Mariana Islands	based on US system except for customs wages immigration laws and taxation
14	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
15	Pakistan	based on English common law with provisions to accommodate Pakistan's status as an Islamic state; accepts compulsory ICJ jurisdiction with reservations
16	Nauru	acts of the Nauru Parliament and British common law
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	Romania	former mixture of civil law system and communist legal theory; is now based on the constitution of France's Fifth Republic
30	Navassa Island	NA
31	Namibia	based on Roman-Dutch law and 1990 constitution
32	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
33	Mali	based on French civil law system and customary law; judicial review of legislative acts in Constitutional Court
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	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
46	Maldives	based on Islamic law with admixtures of English common law primarily in commercial matters; has not accepted compulsory ICJ jurisdiction
47	Malta	based on English common law and Roman civil law; has accepted compulsory ICJ jurisdiction with reservations
48	Myanmar	does not accept compulsory ICJ jurisdiction
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	a combination of Shari'a
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 Organization for Security and Cooperation in Europe
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 statutory law
60	Morocco	based on Islamic law and French and Spanish civil law system; judicial review of legislative acts in Constitutional Chamber of Supreme Court
61	Mozambique	based on Portuguese civil law system and customary law
62	Russia	based on civil law system; judicial review of legislative acts
63	Réunion	French law
64	Kyrgyzstan	based on civil law system
65	U.S. Virgin Islands	based on US laws
66	The Bahamas	based on English common law
67	The Gambia	based on a composite of English common law Koranic law and customary law; accepts compulsory ICJ jurisdiction with reservations
68	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
69	Togo	French-based court system
70	Tokelau	British and local statutes
71	Tonga	based on English law
72	Trinidad and Tobago	based on English common law; judicial review of legislative acts in the Supreme Court; has not accepted compulsory ICJ jurisdiction
73	Tromelin Island	NA
74	Tunisia	based on French civil law system and Islamic law; some judicial review of legislative acts in the Supreme Court in joint session
75	Turkey	derived from various European continental legal systems; accepts compulsory ICJ jurisdiction with reservations
76	Turkmenistan	based on civil law system
77	Turks and Caicos Islands	based on laws of England and Wales with a small number adopted from Jamaica and The Bahamas
78	Tuvalu	NA
79	Uganda	in 1995 the government restored the legal system to one based on English common law and customary law; accepts compulsory ICJ jurisdiction with reservations
80	Tanzania	based on English common law; judicial review of legislative acts limited to matters of interpretation; has not accepted compulsory ICJ jurisdiction
81	Ukraine	based on civil law system; judicial review of legislative acts
82	United Arab Emirates	federal court system introduced in 1971; all emirates except Dubayy
83	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; British courts and legislation are increasingly subject to review by European Union courts
84	United States	based on English common law; judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations
85	Uruguay	based on Spanish civil law system; accepts compulsory ICJ jurisdiction
86	Uzbekistan	evolution of Soviet civil law; still lacks independent judicial system
87	Vanuatu	unified system being created from former dual French and British systems
88	Venezuela	based on Napoleonic code; judicial review of legislative acts in Cassation Court only; has not accepted compulsory ICJ jurisdiction
89	Vietnam	based on communist legal theory and French civil law system
90	Wake Island	NA
91	Wallis and Futuna	French legal system
92	Yemen	based on Islamic law Turkish law English common law and local tribal customary law; does not accept compulsory ICJ jurisdiction
93	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
94	Thailand	based on civil law system with influences of common law; has not accepted compulsory ICJ jurisdiction
95	Tajikistan	based on civil law system; no judicial review of legislative acts
96	Saint Helena	NA
97	Slovenia	based on civil law system
98	Saint Kitts and Nevis	based on English common law
99	Saint Lucia	based on English common law
100	Saint Vincent and the Grenadines	based on English common law
101	Saint-Pierre and Miquelon	French law with special adaptations for local conditions such as housing and taxation
102	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
103	San Marino	based on civil law system with Italian law influences; has not accepted compulsory ICJ jurisdiction
104	Saudi Arabia	based on Islamic law several secular codes have been introduced; commercial disputes handled by special committees; has not accepted compulsory ICJ jurisdiction
105	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
106	Serbia and Montenegro	based on civil law system
107	Seychelles	based on English common law French civil law and customary law
108	Sierra Leone	based on English law and customary laws indigenous to local tribes; has not accepted compulsory ICJ jurisdiction
109	Singapore	based on English common law; has not accepted compulsory ICJ jurisdiction
110	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
111	Solomon Islands	English common law
112	Taiwan	based on civil law system; accepts compulsory ICJ jurisdiction with reservations
113	Somalia	NA
114	South Africa	based on Roman-Dutch law and English common law; accepts compulsory ICJ jurisdiction with reservations
115	South Georgia and the South Sandwich Islands	NA
116	South Korea	combines elements of continental European civil law systems Anglo-American law and Chinese classical thought
117	Spain	civil law system with regional applications; does not accept compulsory ICJ jurisdiction
118	Sri Lanka	a highly complex mixture of English common law Roman-Dutch Muslim Sinhalese and customary law; has not accepted compulsory ICJ jurisdiction
119	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
120	Suriname	based on Dutch legal system incorporating French penal theory
121	Svalbard	NA
122	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
123	Sweden	civil law system influenced by customary law; accepts compulsory ICJ jurisdiction with reservations
124	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
125	Syria	based on Islamic law and civil law system; special religious courts; has not accepted compulsory ICJ jurisdiction
126	Laos	based on traditional customs French legal norms and procedures and Socialist practice
127	Kuwait	civil law system with Islamic law significant in personal matters; has not accepted compulsory ICJ jurisdiction
128	Albania	has not accepted compulsory ICJ jurisdiction
129	Christmas Island	under the authority of the governor general of Australia and Australian law
130	Brunei	based on English common law; for Muslims Islamic Shari'a law supersedes civil law in a number of areas
131	Bulgaria	civil law and criminal law based on Roman law; accepts compulsory ICJ jurisdiction
132	Burkina Faso	based on French civil law system and customary law
133	Burundi	based on German and Belgian civil codes and customary law; does not accept compulsory ICJ jurisdiction
134	Cabo Verde	derived from the legal system of Portugal
135	Cambodia	primarily a civil law mixture of French-influenced codes from the United Nations Transitional Authority in Cambodia
136	Cameroon	based on French civil law system with common law influence; does not accept compulsory ICJ jurisdiction
137	Canada	based on English common law except in Quebec where civil law system based on French law prevails; accepts compulsory ICJ jurisdiction with reservations
138	Cayman Islands	British common law and local statutes
139	Central African Republic	based on French law
140	Chad	based on French civil law system and Chadian customary law; does not accept compulsory ICJ jurisdiction
141	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
142	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
143	Clipperton Island	NA
144	British Indian Ocean Territory	NA
145	Cocos Islands	based upon the laws of Australia and local laws
146	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
147	Comoros	French and Muslim law in a new consolidated code
148	Congo	based on French civil law system and customary law
149	Cook Islands	based on New Zealand law and English common law
150	Coral Sea Islands	the laws of Australia where applicable apply
151	Costa Rica	based on Spanish civil law system; judicial review of legislative acts in the Supreme Court; has not accepted compulsory ICJ jurisdiction
152	Croatia	based on civil law system
153	Cuba	based on Spanish and American law with large elements of Communist legal theory; does not accept compulsory ICJ jurisdiction
154	Cyprus	based on common law with civil law modifications
155	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
156	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
157	Democratic Republic of the Congo	based on Belgian civil law system and tribal law; has not accepted compulsory ICJ jurisdiction
158	British Virgin Islands	English law
159	Brazil	based on Roman codes; has not accepted compulsory ICJ jurisdiction
160	Djibouti	based on French civil law system traditional practices and Islamic law
161	Azerbaijan	based on civil law system
162	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
163	American Samoa	NA
164	Andorra	based on French and Spanish civil codes; no judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
165	Angola	based on Portuguese civil law system and customary law; recently modified to accommodate political pluralism and increased use of free markets
166	Anguilla	based on English common law
167	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
168	Antigua and Barbuda	based on English common law
169	Argentina	mixture of US and West European legal systems; has not accepted compulsory ICJ jurisdiction
170	Armenia	based on civil law system
171	Aruba	based on Dutch civil law system with some English common law influence
172	Ashmore and Cartier Islands	relevant laws of the Northern Territory of Australia
173	Australia	based on English common law; accepts compulsory ICJ jurisdiction with reservations
174	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
175	Bahrain	based on Islamic law and English common law
176	Bouvet Island	NA
177	Baker Island	NA
178	Bangladesh	based on English common law
179	Barbados	English common law; no judicial review of legislative acts
180	Bassas da India	NA
181	Belarus	based on civil law system
182	Belgium	civil law system influenced by English constitutional theory; judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations
183	Belize	English law
184	Benin	based on French civil law and customary law; has not accepted compulsory ICJ jurisdiction
185	Bermuda	English law
186	Bhutan	based on Indian law and English common law; has not accepted compulsory ICJ jurisdiction
187	Bolivia	based on Spanish law and Napoleonic Code; has not accepted compulsory ICJ jurisdiction
188	Bosnia and Herzegovina	based on civil law system
189	Botswana	based on Roman-Dutch law and local customary law; judicial review limited to matters of interpretation; has not accepted compulsory ICJ jurisdiction
190	Denmark	civil law system; judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations
191	Dominica	based on English common law
192	Kiribati	NA
193	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
194	Guyana	based on English common law with certain admixtures of Roman-Dutch law; has not accepted compulsory ICJ jurisdiction
195	Haiti	based on Roman civil law system; accepts compulsory ICJ jurisdiction
196	Heard Island and McDonald Islands	NA
197	Holy See	NA
198	Honduras	rooted in Roman and Spanish civil law; some influence of English common law; accepts ICJ jurisdiction with reservations
199	Hong Kong	based on English common law
200	Howland Island	NA
201	Hungary	in process of revision moving toward rule of law based on Western model
202	Iceland	civil law system based on Danish law; does not accept compulsory ICJ jurisdiction
203	India	based on English common law; limited judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations
204	Indonesia	based on Roman-Dutch law substantially modified by indigenous concepts and by new criminal procedures code; has not accepted compulsory ICJ jurisdiction
205	Iran	the Constitution codifies Islamic principles of government
206	Iraq	based on Islamic law in special religious courts civil law system elsewhere; has not accepted compulsory ICJ jurisdiction
207	Isle of Man	English law and local statute
208	Guinea-Bissau	NA
209	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
210	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
211	Jamaica	based on English common law; has not accepted compulsory ICJ jurisdiction
212	Jan Mayen	NA
213	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
214	Jarvis Island	NA
215	Jersey	English law and local statute
216	Johnston Atoll	NA
217	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
218	Juan de Nova Island	NA
219	Kazakhstan	based on civil law system
220	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
221	Kingman Reef	NA
222	Guinea	based on French civil law system customary law and decree; legal codes currently being revised; has not accepted compulsory ICJ jurisdiction
223	Guernsey	English law and local statute; justice is administered by the Royal Court
224	Dominican Republic	based on French civil codes
225	France	civil law system with indigenous concepts; review of administrative but not legislative acts
226	Ecuador	based on civil law system; has not accepted compulsory ICJ jurisdiction
227	Egypt	based on English common law Islamic law and Napoleonic codes; judicial review by Supreme Court and Council of State
228	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
229	Equatorial Guinea	partly based on Spanish civil law and tribal custom
230	Eritrea	NA
231	Estonia	based on civil law system; no judicial review of legislative acts
232	Ethiopia	currently transitional mix of national and regional courts
233	Europa Island	NA
234	Falkland Islands	English common law
235	Faroe Islands	Danish
236	Federated States of Micronesia	based on adapted Trust Territory laws acts of the legislature municipal common and customary laws
237	Fiji	based on British system
238	Finland	civil law system based on Swedish law; Supreme Court may request legislation interpreting or modifying laws; accepts compulsory ICJ jurisdiction with reservations
239	French Guiana	French legal system
240	Guatemala	civil law system; judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
241	French Polynesia	based on French system
242	French Southern and Antarctic Lands	NA
243	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
244	Georgia	based on civil law system
245	Germany	civil law system with indigenous concepts; judicial review of legislative acts in the Federal Constitutional Court; has not accepted compulsory ICJ jurisdiction
246	Ghana	based on English common law and customary law; has not accepted compulsory ICJ jurisdiction
247	Gibraltar	English law
248	Glorioso Islands	NA
249	Greece	based on codified Roman law; judiciary divided into civil criminal and administrative courts
250	Greenland	Danish
251	Grenada	based on English common law
252	Guadeloupe	French legal system
253	Guam	modeled on US; US federal laws apply
254	Zimbabwe	mixture of Roman-Dutch and English common law

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