Country ranking for field: legal system 2023

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This entry provides the description of a country's legal system. A statement on judicial review of legislative acts is also included for a number of countries. The legal systems of nearly all countries are generally modeled upon elements of five main types: civil law (including French law, the Napoleonic Code, Roman law, Roman-Dutch law, and Spanish law); common law (including United State law); customary law; mixed or pluralistic law; and religious law (including Islamic law). An additional type of legal system - international law, which governs the conduct of independent nations in their relationships with one another - is also addressed below. The following list describes these legal systems, the countries or world regions where these systems are enforced, and a brief statement on the origins and major features of each.


The WorldWorldthe legal systems of nearly all countries are generally modeled upon elements of five main types: civil law
1flag of AfghanistanAfghanistan0 
2flag of PalauPalaumixed legal system of civil common and customary law 
3flag of New ZealandNew Zealandcommon law system based on English model with special legislation and land courts for the Maori 
4flag of NicaraguaNicaraguacivil law system; Supreme Court may review administrative acts 
5flag of NigerNigermixed legal system of civil law based on French civil law Islamic law and customary law 
6flag of NigeriaNigeriamixed legal system of English common law Islamic law 
7flag of NiueNiueEnglish common law 
8flag of Norfolk IslandNorfolk IslandEnglish common law and the laws of Australia 
9flag of North KoreaNorth Koreacivil law system based on the Prussian model; system influenced by Japanese traditions and Communist legal theory 
10flag of North MacedoniaNorth Macedoniacivil law system; judicial review of legislative acts 
11flag of Northern Mariana IslandsNorthern Mariana Islandsthe laws of the US apply except for customs and some aspects of taxation 
12flag of NorwayNorwaymixed legal system of civil common and customary law; Supreme Court can advise on legislative acts 
13flag of OmanOmanmixed legal system of Anglo-Saxon law and Islamic law 
14flag of PakistanPakistancommon law system with Islamic law influence 
15flag of PanamaPanamacivil law system; judicial review of legislative acts in the Supreme Court of Justice 
16flag of NepalNepalEnglish common law and Hindu legal concepts; note - new criminal and civil codes came into effect on 17 August 2018 
17flag of Papua New GuineaPapua New Guineamixed legal system of English common law and customary law 
18flag of ParaguayParaguaycivil law system with influences from Argentine Spanish Roman and French civil law models; judicial review of legislative acts in Supreme Court of Justice 
19flag of PeruPerucivil law system 
20flag of PhilippinesPhilippinesmixed legal system of civil common Islamic 
21flag of Pitcairn IslandsPitcairn Islandslocal island by-laws 
22flag of PolandPolandcivil law system; judicial review of legislative administrative and other governmental acts; constitutional law rulings of the Constitutional Tribunal are final 
23flag of PortugalPortugalcivil law system; Constitutional Court review of legislative acts 
24flag of Puerto RicoPuerto Ricocivil law system based on the Spanish civil code and within the framework of the US federal system 
25flag of QatarQatarmixed legal system of civil law and Islamic 
26flag of RomaniaRomaniacivil law system 
27flag of RussiaRussiacivil law system; judicial review of legislative acts 
28flag of RwandaRwandamixed legal system of civil law based on German and Belgian models and customary law; judicial review of legislative acts in the Supreme Court 
29flag of Saint HelenaSaint HelenaEnglish common law and local statutes 
30flag of New CaledoniaNew Caledoniacivil law system based on French civil law 
31flag of Navassa IslandNavassa Islandthe laws of the US apply where applicable 
32flag of Saint LuciaSaint LuciaEnglish common law 
33flag of MaliMalicivil law system based on the French civil law model and influenced by customary law; judicial review of legislative acts in the Constitutional Court 
34flag of LebanonLebanonmixed legal system of civil law based on the French civil code Ottoman legal tradition and religious laws covering personal status marriage divorce and other family relations of the Jewish Islamic and Christian communities 
35flag of LesothoLesothomixed legal system of English common law and Roman-Dutch law; judicial review of legislative acts in High Court and Court of Appeal 
36flag of LiberiaLiberiamixed legal system of common law based on Anglo-American law and customary law 
37flag of LibyaLibyaLibya's post-revolution legal system is in flux and driven by state and non-state entities 
38flag of LiechtensteinLiechtensteincivil law system influenced by Swiss Austrian and German law 
39flag of LithuaniaLithuaniacivil law system; legislative acts can be appealed to the Constitutional Court 
40flag of LuxembourgLuxembourgcivil law system 
41flag of MacauMacaucivil law system based on the Portuguese model 
42flag of MadagascarMadagascarcivil law system based on the old French civil code and customary law in matters of marriage family and obligation 
43flag of MalawiMalawimixed legal system of English common law and customary law; judicial review of legislative acts in the Supreme Court of Appeal 
44flag of MalaysiaMalaysiamixed legal system of English common law Islamic law 
45flag of MaldivesMaldivesIslamic 
46flag of MaltaMaltamixed legal system of English common law and civil law based on the Roman and Napoleonic civil codes; subject to European Union law 
47flag of NauruNaurumixed legal system of common law based on the English model and customary law 
48flag of Marshall IslandsMarshall Islandsmixed legal system of US and English common law customary law and local statutes 
49flag of MauritaniaMauritaniamixed legal system of Islamic and French civil law 
50flag of MauritiusMauritiuscivil legal system based on French civil law with some elements of English common law 
51flag of MexicoMexicocivil law system with US constitutional law influence; judicial review of legislative acts 
52flag of MoldovaMoldovacivil law system with Germanic law influences; Constitutional Court review of legislative acts 
53flag of MonacoMonacocivil law system influenced by French legal tradition 
54flag of MongoliaMongoliacivil law system influenced by Soviet and Romano-Germanic legal systems; constitution ambiguous on judicial review of legislative acts 
55flag of MontenegroMontenegrocivil law 
56flag of MontserratMontserratEnglish common law 
57flag of MoroccoMoroccomixed legal system of civil law based on French civil law and Islamic 
58flag of MozambiqueMozambiquemixed legal system of Portuguese civil law and customary law 
59flag of MyanmarMyanmarmixed legal system of English common law 
60flag of NamibiaNamibiamixed legal system of uncodified civil law based on Roman-Dutch law and customary law 
61flag of Saint Kitts and NevisSaint Kitts and NevisEnglish common law 
62flag of Saint Vincent and the GrenadinesSaint Vincent and the GrenadinesEnglish common law 
63flag of LaosLaoscivil law system similar in form to the French system 
64flag of UgandaUgandamixed legal system of English common law and customary law 
65flag of The GambiaThe Gambiamixed legal system of English common law Islamic law and customary law 
66flag of The NetherlandsThe Netherlandscivil law system based on the French system; constitution does not permit judicial review of acts of the States General 
67flag of TogoTogocustomary law system 
68flag of TokelauTokelaucommon law system of New Zealand 
69flag of TongaTongaEnglish common law 
70flag of Trinidad and TobagoTrinidad and TobagoEnglish common law; judicial review of legislative acts in the Supreme Court 
71flag of TunisiaTunisiamixed legal system of civil law based on the French civil code and Islamic 
72flag of TurkeyTurkeycivil law system based on various European legal systems notably the Swiss civil code 
73flag of TurkmenistanTurkmenistancivil law system with Islamic 
74flag of Turks and Caicos IslandsTurks and Caicos Islandsmixed legal system of English common law and civil law 
75flag of TuvaluTuvalumixed legal system of English common law and local customary law 
76flag of U.S. Virgin IslandsU.S. Virgin IslandsUS common law 
77flag of UkraineUkrainecivil law system; judicial review of legislative acts 
78flag of ThailandThailandcivil law system with common law influences 
79flag of United Arab EmiratesUnited Arab Emiratesmixed legal system of Islamic 
80flag of United KingdomUnited Kingdomcommon law system; has nonbinding judicial review of Acts of Parliament under the Human Rights Act of 1998 
81flag of United States Pacific Island Wildlife RefugesUnited States Pacific Island Wildlife Refugesthe laws of the US apply where applicable 
82flag of United StatesUnited Statescommon law system based on English common law at the federal level; state legal systems based on common law except Louisiana where state law is based on Napoleonic civil code; judicial review of legislative acts 
83flag of UruguayUruguaycivil law system based on the Spanish civil code 
84flag of UzbekistanUzbekistanflag of Côte d'IvoireCôte d'Ivoirecivil law system based on the French civil code; judicial review of legislation held in the Constitutional Chamber of the Supreme Court 
187flag of DenmarkDenmarkcivil law; judicial review of legislative acts 
188flag of KuwaitKuwaitmixed legal system consisting of English common law French civil law and Islamic sharia law 
189flag of IranIranreligious legal system based on secular and Islamic law 
190flag of Guinea-BissauGuinea-Bissaumixed legal system of civil law which incorporated Portuguese law at independence and influenced by Economic Community of West African States 
191flag of GuineaGuineacivil law system based on the French model 
192flag of GuyanaGuyanacommon law system based on the English model with some Roman-Dutch civil law influence 
193flag of HaitiHaiticivil law system strongly influenced by Napoleonic Code 
194flag of Heard Island and McDonald IslandsHeard Island and McDonald Islandsthe laws of Australia apply where applicable 
195flag of Holy SeeHoly Seereligious legal system based on canon 
196flag of HondurasHondurascivil law system 
197flag of Hong KongHong Kongmixed legal system of common law based on the English model and Chinese customary law 
198flag of HungaryHungarycivil legal system influenced by the German model 
199flag of IcelandIcelandcivil law system influenced by the Danish model 
200flag of IndiaIndiacommon law system based on the English model; separate personal law codes apply to Muslims Christians and Hindus; judicial review of legislative acts 
201flag of IndonesiaIndonesiacivil law system based on the Roman-Dutch model and influenced by customary law 
202flag of IraqIraqmixed legal system of civil and Islamic law 
203flag of GuatemalaGuatemalacivil law system; judicial review of legislative acts 
204flag of IrelandIrelandcommon law system based on the English model but substantially modified by customary law; judicial review of legislative acts by Supreme Court 
205flag of Isle of ManIsle of Manthe laws of the UK apply where applicable and include Manx statutes 
206flag of IsraelIsraelmixed legal system of English common law British Mandate regulations and Jewish Christian and Muslim religious laws 
207flag of ItalyItalycivil law system; judicial review of legislation under certain conditions in Constitutional Court 
208flag of JamaicaJamaicacommon law system based on the English model 
209flag of Jan MayenJan Mayenthe laws of Norway apply where applicable  
210flag of JapanJapancivil law system based on German model; system also reflects Anglo-American influence and Japanese traditions; judicial review of legislative acts in the Supreme Court 
211flag of JerseyJerseythe laws of the UK apply where applicable; includes local statutes 
212flag of JordanJordanmixed system developed from codes instituted by the Ottoman Empire 
213flag of KazakhstanKazakhstancivil law system influenced by Roman-Germanic law and by the theory and practice of the Russian Federation 
214flag of KenyaKenyamixed legal system of English common law Islamic law and customary law; judicial review in the new Supreme Court established by the new constitution 
215flag of KiribatiKiribatiEnglish common law supplemented by customary law 
216flag of KosovoKosovocivil law system; note - the European Union Rule of Law Mission 
217flag of GuernseyGuernseycustomary legal system based on Norman customary law; includes elements of the French civil code and English common law 
218flag of GuamGuamcommon law modeled on US system; US federal laws apply 
219flag of DhekeliaDhekelialaws applicable to the Cypriot population are as far as possible the same as the laws of the Republic of Cyprus; note - the Sovereign Base Area Administration has its own court system to deal with civil and criminal matters 
220flag of Falkland IslandsFalkland IslandsEnglish common law and local statutes 
221flag of DjiboutiDjiboutimixed legal system based primarily on the French civil code 
222flag of DominicaDominicacommon law based on the English model 
223flag of Dominican RepublicDominican Republiccivil law system based on the French civil code; Criminal Procedures Code modified in 2004 to include important elements of an accusatory system 
224flag of East TimorEast Timorcivil law system based on the Portuguese model; note - penal and civil law codes to replace the Indonesian codes were passed by Parliament and promulgated in 2009 and 2011 respectively 
225flag of EcuadorEcuadorcivil law based on the Chilean civil code with modifications; traditional law in indigenous communities 
226flag of EgyptEgyptmixed legal system based on Napoleonic civil and penal law Islamic religious law and vestiges of colonial-era laws; judicial review of the constitutionality of laws by the Supreme Constitutional Court 
227flag of El SalvadorEl Salvadorcivil law system with minor common law influence; judicial review of legislative acts in the Supreme Court 
228flag of Equatorial GuineaEquatorial Guineamixed system of civil and customary law 
229flag of EritreaEritreamixed legal system of civil customary and Islamic religious law 
230flag of EstoniaEstoniacivil law system 
231flag of EswatiniEswatinimixed legal system of civil common and customary law 
232flag of EthiopiaEthiopiacivil law system 
233flag of European UnionEuropean Unionunique supranational system of laws in which according to an interpretive declaration of member-state governments appended to the Treaty of Lisbon "the Treaties and the law adopted by the Union on the basis of the Treaties have primacy over the law of Member States" under conditions laid down in the case law of the Court of Justice; key principles of EU jurisprudence include universal rights as guaranteed by the Charter of Fundamental Rights and as resulting from constitutional traditions common to the EU's 27 member states; EU law is divided into 'primary' and 'secondary' legislation; primary legislation is derived from the consolidated versions of the Treaty on European Union and the Treaty on the Functioning of the European Union and are the basis for all EU action; secondary legislation - which includes directives regulations and decisions - is derived from the principles and objectives set out in the treaties 
234flag of Faroe IslandsFaroe Islandsthe laws of Denmark apply where applicable 
235flag of GrenadaGrenadacommon law based on English model 
236flag of Federated States of MicronesiaFederated States of Micronesiamixed legal system of common and customary law 
237flag of FijiFijicommon law system based on the English model 
238flag of FinlandFinlandcivil law system based on the Swedish model 
239flag of FranceFrancecivil law; review of administrative but not legislative acts 
240flag of French PolynesiaFrench Polynesiathe laws of France where applicable apply 
241flag of French Southern and Antarctic LandsFrench Southern and Antarctic Landsthe laws of France where applicable apply 
242flag of GabonGabonmixed legal system of French civil law and customary law 
243flag of GeorgiaGeorgiacivil law system 
244flag of GermanyGermanycivil law system 
245flag of GhanaGhanamixed system of English common law and customary law 
246flag of GibraltarGibraltarthe laws of the UK where applicable apply 
247flag of GreeceGreececivil legal system based on Roman law 
248flag of GreenlandGreenlandthe laws of Denmark apply where applicable and Greenlandic law applies to other areas 
249flag of ZimbabweZimbabwemixed legal system of English common law Roman-Dutch civil law and customary law 


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