List of national legal systems

Legal systems of the world

The contemporarynational legal systemsare generally based on one of four basicsystems:civil law,common law,customary law,religious lawor combinations of these. However, the legal system of each country is shaped by its unique history and so incorporates individual variations.The science that studies law at the level of legal systems is calledcomparative law.

Bothcivil(also known asRoman) andcommonlaw systems can be considered the most widespread in the world: civil law because it is the most widespread by landmass and by population overall, and common law because it is employed by the greatest number of people compared to any single civil law system.

Civil law

Main article:Civil law (legal system)

Shamash(theBabyloniansun god) hands KingHammurabiacode of law.

The source of law that is recognized as authoritative iscodificationsin a constitution orstatutepassed bylegislature,to amend a code. While the concept of codification dates back to theCode of HammurabiinBabylonca. 1790 BC, civil law systems derive from theRoman Empireand, more particularly, theCorpus Juris Civilisissued by the EmperorJustinianca. AD 529. This was an extensive reform of the law in theByzantine Empire,bringing it together into codified documents. Civil law was also partly influenced byreligious lawssuch asCanon lawandIslamic law.Civil law today, in theory, is interpreted rather than developed or made by judges. Onlylegislativeenactments (rather than legalprecedents,as in common law) are considered legally binding.

Scholars ofcomparative lawand economists promoting thelegal origins theoryusually subdivide civil law into distinct groups:

• French civil law:in France, theBeneluxcountries, Italy, Romania, Spain and former colonies of those countries, mainly in Latin America, Africa and the Middle East;
• German civil law:in Germany, Austria, Russia, Switzerland, Estonia, Latvia, Bosnia and Herzegovina, Croatia, Kosovo*, North Macedonia, Montenegro, Slovenia, Serbia, Greece,Portugalandits former colonies,Turkey, and East Asian countries including Japan, South Korea, and Taiwan (Republic of China);
• Scandinavian civil law:inNorthern Europesuch as Denmark, Norway, Finland, Iceland and Sweden. As historically integrated into the Scandinavian cultural sphere, Finland and Iceland also inherited the system, although especially Icelandhas its ownlegal roots. Scandinavian orNordiccivil law exhibit least similar treats with other civil law systems and is sometimes considered a legal system in its own right, despite reception from mainly German civil law.

However, some of these legal systems are often and more correctly said to be of hybrid nature:

• Napoleonic to Germanistic influence (Italian civil law)

TheItaliancivil code of 1942 replaced the original one of 1865, introducing germanistic elements due to the geopolitical alliances of the time.The Italian approach has been imitated by other countries includingPortugal(1966), theNetherlands(1992),Lithuania(2000),Brazil(2002) andArgentina(2014). Most of them have innovations introduced by the Italian legislation, including the unification of thecivilandcommercial codes.

• Germanistic to Napoleonic influence (Swiss civil law)

TheSwiss civil codeis considered mainly influenced by the German civil code and partly influenced by the French civil code. The civil code of theRepublic of Turkeyis a slightly modified version of the Swiss code, adopted in 1926 duringMustafa Kemal Atatürk's presidency as part of the government's progressive reforms and secularization.

A comprehensive list of countries that base their legal system on acodifiedcivil law follows:

Country	Description
Albania	Based on Napoleonic civil law.
Angola	Based onPortuguese civil law.
Argentina	The Spanish legal tradition had a great influence on theCivil Code of Argentina,basically a work of the ArgentinejuristDalmacio Vélez Sársfield,who dedicated five years of his life to this task. The Civil Code came into effect on 1 January 1871. Beyond the influence of the Spanish legal tradition, the Argentinian Civil Code was also inspired by the Draft of the Brazilian Civil Code, theDraftof the Spanish Civil Code of 1851, theNapoleonic codeand theChilean Civil Code.The sources of this Civil Code also include various theoretical legal works, mainly of the great French jurists of the 19th century. It was the first Civil Law that consciously adopted as its cornerstone the distinction between i. rights from obligations and ii. real property rights, thus distancing itself from the French model. The Argentinian Civil Code was also in effect in Paraguay, as per aParaguayanlaw of 1880, until the new Civil Code went into force in 1987. In Argentina, this 1871 Civil Code remained in force until August 2015, when it was replaced by the newCódigo Civil y Comercial de la Nación. During the second half of the 20th century, theGermanlegal theory became increasingly influential in Argentina.
Andorra	Courts apply the customary laws of Andorra, supplemented with Roman law and customary Catalan law.
Armenia	Based on Napoleonic Civil law and traditional Armenian law.
Aruba	Based on Dutch civil law
Austria	Based on Roman and Germanic Civil law. TheAllgemeines bürgerliches Gesetzbuch(ABGB) of 1811. The ABGB is influenced both by Roman and Austrian law traditions. Comparable to the Napoleonic code, it is based on the ideals of freedom and equality before the law.
Azerbaijan	Based on German, French, Russian, and traditional Azerbaijani Law
Belarus	Based on Germanic Civil law (administrative,criminalcodes)
Belgium	TheNapoleonic Codeis still in use, although it is heavily modified (especially concerning family law)
Benin	Based on Napoleonic Civil law.
Bolivia	Influenced by theNapoleonic Code
Bosnia and Herzegovina	Influenced byAustrian law.The Swiss civil law (Zivilgesetzbuch) was a model for the Law on Obligations of 1978.
Brazil	Based on German, Italian, French and Portuguese law. However, in 2004 theFederal Constitutionwas amended to grant theSupreme Federal Courtauthority to issue binding precedents (súmulas vinculantes) to settle controversies involving constitutional law – a mechanism that echoes thestare decisisprinciple typically found in common law systems.
Bulgaria	Civil Law system influenced by Germanic and Roman law systems
Burkina Faso	Based on the French civil law
Burundi	Based on the French civil law
Chad	Based on the French civil law
People's Republic of China	Based on Germanic Civil law and France Civil law, also with influences from theSoviet Socialist lawfromSoviet Union
Republic of the Congo	Based on the Napoleonic Civil law.
Democratic Republic of the Congo	Based on Belgian civil law
Cambodia
Cape Verde	Based on Portuguese civil law
Central African Republic	Based on the French civil law system
Chile	Based on the Chilean Civil Law inspired by the Napoleonic Civil Law. The Spanish legal tradition exercised an especially great influence on the civil code of Chile. On its turn, the Chilean civil code influenced to a large degree the drafting of the civil codes of otherLatin-Americanstates. For instance, the codes of Ecuador (1861) and Colombia (1873) constituted faithful reproductions of the Chilean code, but for very few exceptions. The compiler of theCivil Code of Chile,VenezuelanAndrés Bello,worked for its completion for almost 30 years, using elements, of the Spanish law on the one hand, and of otherWestern laws,especially of the French one, on the other. It is noted that he consulted and used all of the codes that had been issued till then, starting from the era ofJustinian. The Civil Code came into effect on 1 January 1857. The influence of theNapoleonic codeand the Law of Castile of the Spanish colonial period (especially theSiete Partidas), is great; it is observed however thate.g.in many provisions ofpropertyorcontract law,the solutions of the Frenchcode civilwere put aside in favor of pureRoman lawor Castilian law.
Colombia	Based on the Chilean Civil Law. Civil code introduced in 1873. Nearly faithful reproduction of theChilean civil code
Costa Rica	Based on the Napoleonic Civil Law. First Civil Code (a part of the General Code orCarrilloCode) came into effect in 1841; its text was inspired by the South Peruvian Civil Code of MarshalAndres de Santa Cruz.The present Civil Code went into effect 1 January 1888 and was influenced by theNapoleonic Codeand the Spanish Civil Code of 1889 (from its 1851 draft version).
Croatia	Based on the Germanic Civil Law. The Croatian Law system is largely influenced by German and Austrian law systems. It is significantly influenced by theCivil Code of the Austrian Empirefrom 1811, known in Croatia as"General Civil Law"( "Opći građanski zakon" ).OGZ was in force from 1853to 1946. After theWorld War II,Croatia becomes a member of theYugoslav Federationwhich enacted in 1946 the"Law on immediate voiding of regulations passed before April 6, 1941, and during the enemy occupation"( "Zakon o nevaženju pravnih proposal donesenih prije 6. travnja 1941. i za vrijeme neprijateljske okupacije" ).By this law, OGZ was declared invalid as a whole, but the implementation of some of its legal rules was approved. During the post-War era, the Croatian legal system become influenced by elements of thesocialist law.Croatian civil law was pushed aside, and it took norms of public law and legal regulation of thesocial ownership.After Croatia declared independence from Yugoslavia on 25 June 1991, the previous legal system was used as a base for writing new laws."The Law on Obligations"( "Zakon o obveznim odnosima" )was enacted in 2005.Today, Croatia as aEuropean Unionmember state implements elements of theEU acquisinto its legal system.
Cuba	Influenced by Spanish and American law with large elements ofCommunist legal theory.
Curaçao	Based on Dutch Civil Law.
Czech Republic	Based on Germanic civil law. Descended from theCivil Code of the Austrian Empire(1811), influenced by German (1939–45) and Soviet (1947/68–89) legal codes during occupation periods, substantially reformed to remove Soviet influence and elements ofsocialist lawafter theVelvet Revolution(1989). The new Civil Code of the Czech Republic was introduced in 2014, reestablishing the norms of the ABGB, an reintroducing terms and concepts from it.
Denmark	Based onNorth Germanic law.Scandinavian-North Germanic civil law.
Dominican Republic	Based on theNapoleonic Code
Ecuador	Based on the Chilean civil law. Civil code introduced in 1861.
El Salvador	Based on law.
Estonia	Based on German civil law.
Finland	Based on Nordic law.
France	Based onNapoleonic code(code civilof 1804)
Egypt	Based on Napoleonic civil law and Islamic law.
Equatorial Guinea
Ethiopia
Gabon	Based on the French civil law system
Guinea	Based on French civil law system, customary law, and decree
Guinea-Bissau	Based on Portuguese civil law
Georgia
Germany	Based on Germanic civil law. TheBürgerliches Gesetzbuchof 1900 ( "BGB" ). The BGB is influenced both by Roman and German law traditions.
Greece	Based on Germanic civil law. The Greekcivil codeof 1946, highly influenced by traditional Roman law and the German civil code of 1900 (Bürgerliches Gesetzbuch); the Greek civil code replaced theByzantine–Roman civil lawin effect in Greece since its independence (Νομική Διάταξη της Ανατολικής Χέρσου Ελλάδος, Legal Provision of Eastern Mainland Greece, November 1821: 'Οι Κοινωνικοί Νόμοι των Αειμνήστων Χριστιανών Αυτοκρατόρων της Ελλάδος μόνοι ισχύουσι κατά το παρόν εις την Ανατολικήν Χέρσον Ελλάδα', 'The Social [i.e. Civil] Laws of the Dear Departed Christian Emperors of Greece [referring to the Byzantine Emperors] alone are in effect at present in Eastern Mainland Greece')
Guatemala	Based on Napoleonic civil law. Guatemala has had three Civil Codes: the first one from 1877, a new one introduced in 1933, and the one currently in force, which was passed in 1963. This Civil Code has suffered some reforms throughout the years, as well as a few derogations relating to areas that have subsequently been regulated by newer laws, such as the Code of Commerce and the Law of the National Registry of Persons. In general, it follows the tradition of the Roman-French system of civil codification. Regarding the theory of 'sources of law' in the Guatemalan legal system, the 'Ley del Organismo Judicial' recognizes 'the law' as the main legal source (in the sense of legislative texts), although it also establishes 'jurisprudence' as a complementary source. Although jurisprudence technically refers to judicial decisions in general, in practice it tends to be confused and identified with the concept of 'legal doctrine', which is a qualified series of identical resolutions in similar cases pronounced by higher courts (the Constitutional Court acting as a 'Tribunal deAmparo', and the Supreme Court acting as a 'Tribunal de Casación') whose theses become binding for lower courts.
Haiti	Based on Napoleonic civil law.
Honduras
Hungary	Based on Germanic, codifiedRoman lawwith elements from Napoleonic civil law.
Iceland	Based onNorth Germanic law.Germanic traditional laws and influenced by Medieval Norwegian and Danish laws.
India(former French and Portuguese colonies)	Based on Portuguese civil law (Goa,andDadra and Nagar Haveli and Daman and Diu), and French civil law (Puducherry).Vedic Hindu legal traditionsalso influenced the legal system in India.
Italy	Based on Germanic civil law, with elements of theNapoleonic civil code;civil code of 1942 replaced the original one of 1865
Ivory Coast	Based on French civil law system
Japan	Based on Germanic civil law. Japanese civil code of 1895.
Latvia	Based on Napoleonic and German civil law, as it was historically before the Soviet occupation. While general principles of law are prerequisites in making and interpreting the law, case law is also regularly applied to present legal arguments in courts and explain the application of law in similar cases. Civil law largely modeled after the Napoleonic code mixed with strong elements of German civil law. Criminal law retains Russian and German legal traditions, while criminal procedure law has been fully modeled after practice accepted in Western Europe. The civil law of Latvia enacted in 1937.
Lebanon	Based on Napoleonic civil law.
Lithuania	Modeled after Dutch civil law
Louisiana (U.S.)	Law in the state of Louisiana is based on French and Spanish civil law. Federal courts and 49 states use the legal system based on English common law (see below), which has diverged somewhat since the mid-nineteenth century in that they look to each other's cases for guidance on issues of the first impression and rarely look at contemporary cases on the same issue in the UK or the Commonwealth.
Luxembourg	Based on Napoleonic civil law.
Macau(P.R.China)	Principally based on Portuguese civil law, also influenced by PRC law.
Mexico	Based on Napoleonic civil law. "The origins of Mexico's legal system are both ancient and classical, based on the Roman and French legal systems, and the Mexican system shares more in common with other legal systems throughout the world (especially those in Latin America and most of continental Europe)..."
Mongolia	Based on Germanic civil law.
Montenegro	Based on Napoleonic and German civil law. First: the General Property Code for thePrincipality of Montenegroof 1888, written byValtazar Bogišić.Present: the Law on Obligations of 2008.
Mozambique	Based on Portuguese civil law
Netherlands	Based onNapoleonic code with German law influence
Nepal	Based onCivil Code,however, the principle ofstare decisisis widely practised. The legal system of Nepal has been influenced byBritish Legal System
Norway	Scandinavian-North Germanic civil law, based onNorth Germanic law.KingMagnus VI the Lawmenderunified the regional laws into a single code of law for the whole kingdom in 1274. This was replaced byChristian V'sNorwegian Codeof 1687.
Panama
Paraguay	The Paraguayan Civil Code in force since 1987 is largely influenced by the Napoleonic Code and the Argentinian Code
Peru	Based on civil law system. accepts compulsory International Court of Justice ICJ jurisdiction with despotic and corrupting reservations.
Poland	The Polish Civil Code in force since 1965
Portugal	Influenced by theNapoleonic Codeand later by the German civil law
Taiwan(Republic of China)	Influenced by GermanCivil Codeand JapaneseSix Codes.Enacted in 1931.
Romania	Civil Codecame into force in 2011. Based on the Civil Code of Quebec, but also influenced by the Napoleonic Code and other French-inspired codes (such as those of Italy, Spain and Switzerland)
Russia	Civil Law system descendant fromRoman LawthroughByzantinetradition. Heavily influenced by German and Dutch norms in the 1700s. Socialism-style modifications from 1920s on, and Continental European Civil Law influences since the 1990s.
Rwanda	Mixture of Belgian civil law and English common law
São Tomé e Príncipe	Based on Portuguese civil law
Serbia	First: theCivil CodeofPrincipality of Serbiaof 1844, written by Jovan Hadžić, was influenced by the Austrian Civil Code (Allgemeines bürgerliches Gesetzbuch). Present: The Swiss civil law (Zivilgesetzbuch) was a model for the Law on Obligations of 1978.
Slovakia	Descended from theCivil Code of the Austrian Empire(1811), influenced by German (1939–45) and Soviet (1947/68–89) legal codes during occupation periods, substantially reformed to remove Soviet influence and elements ofsocialist lawafter theVelvet Revolution(1989).
Slovenia	A Civil Law system influenced mostly by Germanic and Austro-Hungarian law systems
South Korea	Based on the German civil law system. Also largely influenced by Japanese civil law which itself modeled after the German one.Korean Civil Codewas introduced 1958 and fully enacted by 1960.
Spain	Influenced by theNapoleonic Code,it also has some elements of Spain's legal tradition, starting with theSiete Partidas,major legislative achievement from the Middle Ages. That body of law remained more or less unchanged until the 19th century when the first civil codes were drafted, merging both the Napoleonic style with the Castilian traditions.
Suriname	Based on Dutch civil law
Sweden	Scandinavian-North Germanic civil law. Like all Scandinavian legal systems, it is distinguished by its traditional character and for the fact that it did not adopt elements of Roman law. It assimilated very few elements of foreign laws whatsoever. The Napoleonic Code had no influence in the codification of law in Scandinavia. The historical basis of the law of Sweden, just as for all Nordic countries, isNorth Germanic law.Codification of the law started in Sweden during the 18th century, preceding the codifications of most other European countries. However, neither Sweden nor any other Nordic state created a civil code of the kind of theCode Civilor the BGB.
Switzerland	TheSwiss Civil Codeof 1908 and 1912 (obligations; fifth book)
Syria	Based on Napoleonic civil law.
Timor-Leste	Based on Portuguese civil law
Turkey	Modeled after the Swiss civil law (Zivilgesetzbuch) of 1907.
Ukraine	Based on German civil law and was accepted in 2004.
Uruguay	The basis for itspublic lawis the1967 Constitution,amended in 1989, 1994,1996,and 2004. There is a clear separation of functions between the three administrative powers.Private relationships are governed by theUruguayan Civil Code.
Uzbekistan	Represents an evolution ofSovietcivil law. The overwhelmingly strong impact of the Communist legal theory is traceable.
Vietnam	Based onCommunist legal theory,influenced byFrench civil law.
Venezuela	Based on Napoleonic civil law. Spanish legal traditions also influenced the civil law system in Venezuela.

Common law

Main article:Common law

King John of England signsMagna Carta.

Common law andequityare systems of law whose sources are the decisions in cases by judges. In addition, every system will have a legislature that passes new laws and statutes. The relationships between statutes and judicial decisions can be complex. In some jurisdictions, such statutes may overrule judicial decisions or codify the topic covered by several contradictory or ambiguous decisions. In some jurisdictions, judicial decisions may decide whether the jurisdiction's constitution allowed a particular statute or statutory provision to be made or what meaning is contained within the statutory provisions. The common law developed in England, influenced byAnglo-Saxonlaw and to a much lesser extent by theNorman conquest of England,which introduced legal concepts fromNorman law,which, in turn, had its origins inSalic law.Common law was later inherited by theCommonwealth of Nations,and almost every former colony of theBritish Empirehas adopted it (Maltabeing an exception). The doctrine ofstare decisis,also known ascase laworprecedentby courts,is the major difference to codified civil law systems.

Common law is practiced inCanada(excludingQuebec),Australia,New Zealand,most of theUnited Kingdom(England, Wales,andNorthern Ireland),South Africa,Ireland,India(excludingGoaand Puducherry),Pakistan,Hong Kong,theUnited States(on state and territorial levels excludingLouisianaandPuerto Rico),Bangladesh,and many other places. Several others have adapted the common law system into a mixed system; For example, Nigeria operates largely on a common law system in the southern states and at the federal level, but also incorporates religious law in the northern states.

In theEuropean Union,theCourt of Justicetakes an approach mixing civil law (based on the treaties) with an attachment to the importance of case law. One of the most fundamental documents to shape common law is the EnglishMagna Carta,which placed limits on the power of the English Kings. It served as a kind of medieval bill of rights for the aristocracy and the judiciary who developed the law.

Country	Description
American Samoa	Based onlaw of the United States.
Antigua and Barbuda	Based on English common law.
Australia	Based on English common law.
Bahamas	Based on English common law.
Bangladesh	Based on English common law, with the Muslim family law heavily based on Islamic law (Sharia).
Barbados	Based on English common law.
Belize	Based on English common law.
Bhutan	Based on English common law, with an Indian influence. Religious law influences personal law.
British Virgin Islands	Based on English common law.
Canada	Based on English common law, except inQuebec,wherea civil law systembased onFrench lawprevails in most matters of a civil nature, such as obligations (contract and delict), property law, family law, and private matters. Federal statutes take into account the juridical nature of Canada and use both common law and civil law terms where appropriate.
Cayman Islands	Based on English common law.
Cyprus	Based on English common law, as inherited from British colonization, with civil law influences, particularly in criminal law.
Dominica	Based on English common law.
England and Wales (UK)	Primarilycommon law,with earlyRomanand some moderncontinental Europeaninfluences.
Fiji	Based on English common law.
Gibraltar	Based on English common law.
Ghana	Based on English common law.
Grenada	Based on English common law.
Hong Kong(P.R.China)	Principally based on English common law, also influenced by PRC law.
India	Based on English common law, except intermingled laws in Goa,DNHDD and Puducherry.Vedic Hindu legal traditionsalso influenced the legal system in India.
Ireland	Based on Irish law before 1922, which was itself based on English common law.
Israel	Based on English common law, arising from the period of theBritish Mandate(which includes laws arising from previousOttomanrule),also incorporating civil law and fragments ofHalakhaandShariafor family law cases
Jamaica	Based on English common law.
Kiribati	Based on English common law.
Liberia	Based on Anglo-American and customary law
Marshall Islands	Based onlaw of the United States.
Myanmar	Based on English common law.
Nauru	Based on English common law.
Nepal	Based on English common law.
New Zealand	Based on English common law.
Northern Ireland (UK)	Based on Irish law before 1921, in turn, based on English common law.
Palau	Based onlaw of the United States.
Pakistan	Based on English common law, with some provisions of Islamic law.
Papua New Guinea	Based on English common law and customary laws of its more than 750 different cultural and language groups.
Saint Kitts and Nevis	Based on English common law.
Saint Vincent and the Grenadines	Based on English common law.
Singapore	Based on English common law, but Muslims are subject to theAdministration of Muslim Law Act,which gives the Sharia Court jurisdiction over Muslim personal law,e.g.,marriage, inheritance and divorce.
Tonga	Based on English common law.
Trinidad and Tobago	Based on English common law.
Tuvalu	Based on English common law.
Uganda	Based on English common law.
United States	Federal courtsand 49 states use the legal system based on English common law, which has diverged somewhat since the mid-nineteenth century in that they look to each other's cases for guidance on issues of the first impression and rarely if ever, look at contemporary cases on the same issue in the UK or the Commonwealth. Louisianais based on French and Spanish civil law, andPuerto Ricois based on Spanish civil law.

Religious law

Main article:Religious law

Religious law refers to the notion of a religious system or document being used as a legal source, though the methodology used varies. For example, the use of Judaism andhalakhafor public law has a static and unalterable quality, precluding amendment through legislative acts of government or development through judicial precedent; Christiancanon lawis more similar tocivil lawin its use ofcodes;and Islamicsharialaw (andfiqhjurisprudence) is based on legalprecedentand reasoning byanalogy(qiyas), and is thus considered similar tocommon law.

The main kinds of religious law areshariain Islam,halakhain Judaism, andcanon lawin some Christian groups. In some cases these are intended purely as individual moral guidance, whereas in other cases they are intended and may be used as the basis for a country's legal system; the latter was particularly common during theMiddle Ages.

Aleppo Codex: 10th century Hebrew Bible with Masoretic pointing

Halakhais followed byOrthodoxandConservativeJews in both ecclesiastical and civil relations. No country is fully governed byhalakha,but two Jewish people may decide, because of personal belief, to have a dispute heard by a Jewish court, and be bound by its rulings.

Canon lawis the internalecclesiasticallaw, or operational policy, governing theCatholic Church(both theLatin Churchand theEastern Catholic Churches), theEastern OrthodoxandOriental Orthodoxchurches, and the individual national churches within theAnglican Communion.Canon law of the Catholic Church(Latin:jus canonicum)is thesystemoflawsandlegal principlesmade and enforced by thehierarchical authoritiesof the Catholic Church to regulate its external organisation and government and to order and direct the activities of Catholics toward the mission of the church.The canon law of the Catholic Church has all the ordinary elements of a mature legal system: laws,courts,lawyers,judges.The canon law of the Latin Church was the first modern Westernlegal system,and is the oldest continuously functioning legal system in theWest.while the distinctive traditions ofEastern Catholic canon lawgovern the 23 Eastern Catholicparticular churchessui iuris.

The Islamic legal system, consisting ofsharia(Islamic law) andfiqh(Islamic jurisprudence), is the most widely usedreligious lawsystem, and one of the three most common legal systems in the world alongside common law and civil law.It is based on bothdivine law,derived from thehadith of the Quran and Sunnah,and the rulings ofulema(jurists), who use the methods ofijma(consensus),qiyas(analogical deduction),ijtihad(research), andurf(common practice) to derivefatwā(legal opinions). Anulemawas required to qualify for anijazah(legaldoctorate) at amadrasa(law schoolorcollege) before they could issuefatwā.During theIslamic Golden Age,classical Islamic law may have had aninfluence on the developmentof common lawand several civil law institutions.Sharia law governs a number of Islamic countries, including Saudi Arabia and Iran, though most countries use Sharia law only as a supplement to national law. It can relate to all aspects of civil law, including property rights, contracts, and public law.

Country	Description
Afghanistan	Islamic law, based on SunniHanafijurisprudence.
Iran	Islamic law, based on ShiaJaʽfarijurisprudence.
Nigeria	Sharia in the northern states,common lawin the south and at the federal level.
Saudi Arabia	Islamic law.
Yemen	Islamic law.

Pluralistic systems

Civil law and canon law

Main article:Canon law (Catholic Church)

Canon lawis not divine law, properly speaking, because it is not found in revelation. Instead, it is seen as human law inspired by the word of God and applying the demands of that revelation to the actual situation of the church.Canon lawregulates the internal ordering of theCatholic Church,theEastern Orthodox Churchand theAnglican Communion.Canon law is amended and adopted by the legislative authority of the church, such ascouncils of bishops,individual bishops for their respective sees, thePopefor the entire Catholic Church, and the British Parliament for theChurch of England.

Country	Description
Vatican City	Based onRoman&Italiancivil law andCatholic canon law

Civil law and common law

Country	Description
Botswana	Based onSouth African law.An 1891 proclamation by theHigh Commissioner for Southern Africaapplied the law of theCape Colony(now part of South Africa) to theBechuanaland Protectorate(now Botswana).
Cameroon	Mixture of French civil law system and English common law (AfterWorld War I,Cameroon was ruled byFranceand theUnited Kingdomas aLeague of Nations mandatethen aUnited Nations trust territoryfrom 1916 to 1961)
Cyprus	Based on English common law (Cyprus was a British colony 1878–1960), with admixtures of French and Greek civil and public law, Italian civil law, Indian contract law,Greek Orthodoxcanon law and Muslim religious law.
Eswatini	Based onSouth African law.A 1907 proclamation by theHigh Commissioner for Southern Africaapplied the Roman-Dutch common law of theTransvaal Colony(now part of South Africa) to theSwaziland Protectorate(now Eswatini).
Guyana	Guyana follows a mixed legal system, a combination of Civil Law & Common Law.
India	In post-independence India, the Uniform Penal Code throughout India andcivil code to residents of Goa.TheBharatiya Nyaya Sanhita,theBharatiya Nagarik Suraksha Sanhitaand theBharatiya Sakshya Act, 2023amendment bills with minor changes.WhileHindu personal lawbased on customary laws ofIndian religionsandMuslim personal lawbased onhanafischool are currently used,the Indian government is promoting aUniform Civil Codethat applies to all citizens.
Kenya	Based on English Common Law and Civil law as well as the country's customary law.
Lesotho	Based onSouth African law.An 1884 proclamation by theHigh Commissioner for Southern Africaapplied the law of theCape Colony(now part of South Africa) toBasutoland(now Lesotho).
Louisiana (U.S.)	Based on French and Spanish civil law, but federal laws (based on common law) are also in effect in Louisiana because of federalSupremacy Clause.However, Louisiana's criminal law, procedural law and administrative law is predominantly based on the common law tradition.
Malta	Initially based onRoman Lawand eventually progressed to the Code de Rohan, theNapoleonic Codewith influences from Italian Civil Law. English common law however is also a source of Maltese Law, most notably inPublic Law.
Mauritius	Laws governing the Mauritian penal system are derived partly fromFrench civil lawandBritish common law.
Namibia	Based onSouth African law.South Africa conqueredSouth-West Africa(now Namibia) in 1915, and a 1919 proclamation by theGovernor-Generalapplied the law of theCape Provinceof South Africa to the territory.
Philippines	Based on Spanish law; influenced by U.S. common law after 1898Spanish–andPhilippine–American Wars,personal law based onsharialaw applies to Muslims.
Puerto Rico (U.S.)	Based on Spanish law; influenced by U.S. common law after 1898 (victory of the U.S. over Spain in the Spanish–American War of 1898 and cession of Puerto Rico to the U.S.); federal laws (based on common law) are in effect because of federal Supremacy Clause.
Quebec (Canada)	After the 1763Treaty of ParisawardedFrench Canadato Great Britain, the British initially attempted to impose English Common Law. In 1774, as a result of a ruling by the British courts inCampbell v Hallabout the status of legal systems found in acquired territories, the British Parliament passed theQuebec Act,which preserved Frenchcivil lawforprivate lawwhile keeping and reserving Englishcommon lawfor public law including criminal prosecution. Codification occurred in 1866 with the enactment of theCivil Code of Lower Canada(French:Code civil du Bas-Canada), which continued in force when the modern Province of Quebec was created at Confederation in 1867. Subsequently, theCivil Code of Quebec(French:Code civil du Québec) came into effect on 1 January 1994, and is thecivil codecurrently in force. Canadian (federal) criminal law in force in Quebec is based on common law, but federal statutes of or relating to private law take into account the bijuridical nature of Canada and use both common law and civil law terms where appropriate.
Saint Lucia
Scotland (UK)	Based onRomanand continental law, with common law elements dating back to theHigh Middle Ages.
Seychelles	The substantive civil law is based on the French Civil Code. Otherwise, the criminal law and court procedure are based on the English common law. SeeSeychelles Legal Environment.
South Africa	An amalgam ofRoman-Dutch civil lawand Englishcommon law,as well asCustomary Law.
Sri Lanka	An amalgam of English common law,Roman-Dutch civil lawandCustomary Law
Thailand	The Thai legal system became an amalgam of German, Swiss, French, English, Japanese, Italian, Indian and American laws and practices. Even today, Islamic laws and practices exist in four southern provinces. Over the years, Thai law has naturally taken on its own Thai identity.
Vanuatu	Consists of a mixed system combining the legacy of English common law, French civil law and indigenous customary law.
Zimbabwe	Based onSouth African law.An 1891 proclamation by theHigh Commissioner for Southern Africaapplied the law of theCape Colony(now part of South Africa) toSouthern Rhodesia(now Zimbabwe).

Civil law and sharia law

Country	Description
Algeria
Bahrain
Comoros
Djibouti
Egypt	Family Law (personal Statute) for Muslims based on Islamic Jurisprudence, Separate Personal Statute for non-Muslims, and all other branches of Law are based on French civil law system
Eritrea	Only applies to Muslims for personal matters
Indonesia	Based onNapoleonic-Dutch civil law,mixed with Islamicsharialaw, andCustomary Law.
Jordan	Mainly based onFrench Civil Codeand OttomanMajalla,Islamic law applicable to family law
Mauritania	Mix of Islamic law andFrench Civil Codes,Islamic law largely applicable to both criminal, family law, and other forms of personal laws such as disputes.
Mauritius	Civil law and sharia personal law for Muslims.
Morocco	Based on Islamic law and French and Spanish civil law system. Islamic law is mainly for personal matters and Jews use Halakha.
Oman
Qatar	Based on Islamic law and the Egyptian civil law system (after the French civil law system)
Syria	Mainly based onFrench Civil Code.Islamic law is applicable to family law. Non-Muslims follow their own family laws.
United Arab Emirates	Mixed legal system, based on Islamic law and the Egyptian civil law system (after the French civil law system). The UAE adopts a dual legal system of civil and Sharia.

Common law and sharia law

Country	Description
Bangladesh	Based on English common law, personal law based on sharia law applies to Muslims.
Brunei
The Gambia
Malaysia	Based on English common law, personal law based onsharialaw applies to Muslims.
Nigeria	Common law is used at the federal level and in most states,Sharia is applied in some northern states.
Pakistan	Based on English common law, some Islamic law (sharia) applications ininheritance.FormerlyTribal Lawin theFATA.

By geography

Despite the usefulness of different classifications, every legal system has its own individual identity. Below are groups of legal systems, categorised by theirgeographic location.

See also

• Anarchist law
• Comparative law
• English common law
• International customary law
• Sharia
• Qanun (law)
• Legal pluralism
  • Journal of Legal Pluralism
• Rule of law
• Rule According to Higher Law
• Socialist law
• Soviet law
• Tribal sovereignty
• Western law
• Comparative law wiki
• Legal education

Sources

Books

• Moustaira Elina N.,Comparative Law: University Courses (in Greek),Ant. N. Sakkoulas Publishers, Athens, 2004,ISBN960-15-1267-5.
• Moustaira Elina N.,Milestones in the Course of Comparative Law: Thesis and Antithesis (in Greek),Ant. N. Sakkoulas Publishers, Athens, 2003,ISBN960-15-1097-4.
• Palmer, Vernon Valentine, Mohamed Y. Mattar, & Anna Kopper, eds.Mixed Legal Systems, East and West.Farnham–Burlington, VT: Ashgate, 2014.

External links

• World Legal Systems,Website of the Faculty of Law of the University of Ottawa
• Factbook list of legal systems