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World distribution of major legal traditions

Legal system
This entry contains a brief description of the legal system's historical roots, role in government, and acceptance of International Court of Justice (ICJ) jurisdiction.
Source: CIA-World Factbook
 
Country Legal system
Afghanistan the Bonn Agreement calls for a judicial commission to rebuild the justice system in accordance with Islamic principles, international standards, the rule of law, and Afghan legal traditions

 
Akrotiri the laws of the UK, where applicable, apply

 
Albania has not accepted compulsory ICJ jurisdiction

 
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

 
American Samoa NA

 
American Virgin Islands based on US laws

 
Andorra based on French and Spanish civil codes; no judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction

 
Angola based on Portuguese civil law system and customary law; recently modified to accommodate political pluralism and increased use of free markets

 
Anguilla based on English common law

 
Antarctica Antarctica is administered through meetings of the consultative member nations. Decisions from these meetings are carried out by these member nations (within their areas) in accordance with their own national laws. US law, including certain criminal offenses by or against US nationals, such as murder, may apply extra-territorially. Some US laws directly apply to Antarctica. For example, the Antarctic Conservation Act, 16 U.S.C. section 2401 et seq., provides civil and criminal penalties for the following activities, unless authorized by regulation of statute: the taking of native mammals or birds; the introduction of nonindigenous plants and animals; entry into specially protected areas; the discharge or disposal of pollutants; and the importation into the US of certain items from Antarctica. Violation of the Antarctic Conservation Act carries penalties of up to $10,000 in fines and one year in prison. The National Science Foundation and Department of Justice share enforcement responsibilities. Public Law 95-541, the US Antarctic Conservation Act of 1978, as amended in 1996, requires expeditions from the US to Antarctica to notify, in advance, the Office of Oceans and Polar Affairs, Room 5801, Department of State, Washington, DC 20520, which reports such plans to other nations as required by the Antarctic Treaty. For more information, contact Permit Office, Office of Polar Programs, National Science Foundation, Arlington, Virginia 22230; telephone: (703) 292-8030, or visit their website at www.nsf.gov.

 
Antigua and Barbuda based on English common law

 
Argentina mixture of US and West European legal systems; has not accepted compulsory ICJ jurisdiction

 
Armenia based on civil law system

 
Aruba based on Dutch civil law system, with some English common law influence

 
Ashmore and Cartier Islands the laws of the Commonwealth of Australia and the laws of the Northern Territory of Australia, where applicable, apply

 
Australia based on English common law; accepts compulsory ICJ jurisdiction, with reservations

 
Austria civil law system with Roman law origin; judicial review of legislative acts by the Constitutional Court; separate administrative and civil/penal supreme courts; accepts compulsory ICJ jurisdiction

 
Azerbaijan based on civil law system

 
Bahamas, The based on English common law

 
Bahrain based on Islamic law and English common law

 
Baker Island the laws of the US, where applicable, apply

 
Bangladesh based on English common law

 
Barbados English common law; no judicial review of legislative acts

 
Bassas da India the laws of France, where applicable, apply

 
Belarus based on civil law system

 
Belgium civil law system influenced by English constitutional theory; judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations

 
Belize English law

 
Benin based on French civil law and customary law; has not accepted compulsory ICJ jurisdiction

 
Bermuda English law

 
Bhutan based on Indian law and English common law; has not accepted compulsory ICJ jurisdiction

 
Bolivia based on Spanish law and Napoleonic Code; has not accepted compulsory ICJ jurisdiction

 
Bosnia and Herzegovina based on civil law system

 
Botswana based on Roman-Dutch law and local customary law; judicial review limited to matters of interpretation; has not accepted compulsory ICJ jurisdiction

 
Bouvet Island the laws of Norway, where applicable, apply

 
Brazil based on Roman codes; has not accepted compulsory ICJ jurisdiction

 
British Indian Ocean Territory the laws of the UK, where applicable, apply

 
British Virgin Islands English law

 
Brunei based on English common law; for Muslims, Islamic Shari'a law supersedes civil law in a number of areas

 
Bulgaria civil law and criminal law based on Roman law; accepts compulsory ICJ jurisdiction

 
Burkina Faso based on French civil law system and customary law

 
Burma has not accepted compulsory ICJ jurisdiction

 
Burundi based on German and Belgian civil codes and customary law; has not accepted compulsory ICJ jurisdiction

 
Cambodia primarily a civil law mixture of French-influenced codes from the United Nations Transitional Authority in Cambodia (UNTAC) period, royal decrees, and acts of the legislature, with influences of customary law and remnants of communist legal theory; increasing influence of common law in recent years

 
Cameroon based on French civil law system, with common law influence; has not accepted compulsory ICJ jurisdiction

 
Canada based on English common law, except in Quebec, where civil law system based on French law prevails; accepts compulsory ICJ jurisdiction, with reservations

 
Cape Verde derived from the legal system of Portugal

 
Cayman Islands British common law and local statutes

 
Central African Republic based on French law

 
Chad based on French civil law system and Chadian customary law; has not accepted compulsory ICJ jurisdiction

 
Chile based on Code of 1857 derived from Spanish law and subsequent codes influenced by French and Austrian law; judicial review of legislative acts in the Supreme Court; has not accepted compulsory ICJ jurisdiction note: Chile is in the process of completely overhauling its criminal justice system; a new, US-style adversarial system is being gradually implemented throughout the country

 
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

 
Christmas Island under the authority of the governor general of Australia and Australian law

 
Clipperton Island the laws of France, where applicable, apply

 
Cocos (Keeling) Islands based upon the laws of Australia and local laws

 
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

 
Comoros French and Muslim law in a new consolidated code

 
Congo, Democratic Republic of the based on Belgian civil law system and tribal law; has not accepted compulsory ICJ jurisdiction

 
Congo, Republic of the based on French civil law system and customary law

 
Cook Islands based on New Zealand law and English common law

 
Coral Sea Islands the laws of Australia, where applicable, apply

 
Costa Rica based on Spanish civil law system; judicial review of legislative acts in the Supreme Court; has accepted compulsory ICJ jurisdiction

 
Cote 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

 
Croatia based on civil law system

 
Cuba based on Spanish and American law, with large elements of Communist legal theory; has not accepted compulsory ICJ jurisdiction

 
Cyprus based on common law, with civil law modifications

 
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 (OSCE) obligations and to expunge Marxist-Leninist legal theory

 
Denmark civil law system; judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations

 
Dhekelia the laws of the UK, where applicable, apply

 
Djibouti based on French civil law system, traditional practices, and Islamic law

 
Dominica based on English common law

 
Dominican Republic based on French civil codes

 
Ecuador based on civil law system; has not accepted compulsory ICJ jurisdiction

 
Egypt based on English common law, Islamic law, and Napoleonic codes; judicial review by Supreme Court and Council of State (oversees validity of administrative decisions); accepts compulsory ICJ jurisdiction, with reservations

 
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

 
Equatorial Guinea partly based on Spanish civil law and tribal custom

 
Eritrea primary basis is the Ethiopian legal code of 1957, with revisions; new civil, commercial, and penal codes have not yet been promulgated; also relies on customary and post-independence-enacted laws and, for civil cases involving Muslims, Sharia law

 
Estonia based on civil law system; no judicial review of legislative acts

 
Ethiopia currently transitional mix of national and regional courts

 
Europa Island the laws of France, where applicable, apply

 
Falkland Islands (Islas Malvinas) English common law

 
Faroe Islands Danish

 
Fiji based on British system

 
Finland civil law system based on Swedish law; Supreme Court may request legislation interpreting or modifying laws; accepts compulsory ICJ jurisdiction, with reservations

 
France civil law system with indigenous concepts; review of administrative but not legislative acts

 
French Guiana French legal system

 
French Polynesia based on French system

 
French Southern and Antarctic Lands the laws of France, where applicable, apply

 
Gabon based on French civil law system and customary law; judicial review of legislative acts in Constitutional Chamber of the Supreme Court; has not accepted compulsory ICJ jurisdiction

 
Gambia, The based on a composite of English common law, Koranic law, and customary law; accepts compulsory ICJ jurisdiction, with reservations

 
Gaza Strip based on civil law system

 
Georgia based on civil law system

 
Germany civil law system with indigenous concepts; judicial review of legislative acts in the Federal Constitutional Court; has not accepted compulsory ICJ jurisdiction

 
Ghana based on English common law and customary law; has not accepted compulsory ICJ jurisdiction

 
Gibraltar English law

 
Glorioso Islands the laws of France, where applicable, apply

 
Greece based on codified Roman law; judiciary divided into civil, criminal, and administrative courts

 
Greenland Danish

 
Grenada based on English common law

 
Guadeloupe French legal system

 
Guam modeled on US; US federal laws apply

 
Guatemala civil law system; judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction

 
Guernsey English law and local statute; justice is administered by the Royal Court

 
Guinea based on French civil law system, customary law, and decree; legal codes currently being revised; has not accepted compulsory ICJ jurisdiction

 
Guinea-Bissau NA

 
Guyana based on English common law with certain admixtures of Roman-Dutch law; has not accepted compulsory ICJ jurisdiction

 
Haiti based on Roman civil law system; accepts compulsory ICJ jurisdiction

 
Heard Island and McDonald Islands the laws of Australia, where applicable, apply

 
Holy See (Vatican City) NA

 
Honduras rooted in Roman and Spanish civil law with increasing influence of English common law; recent judicial reforms include abandoning Napoleonic legal codes in favor of the oral adversarial system; accepts ICJ jurisdiction, with reservations

 
Hong Kong based on English common law

 
Howland Island the laws of the US, where applicable, apply

 
Hungary rule of law based on Western model

 
Iceland civil law system based on Danish law; has not accepted compulsory ICJ jurisdiction

 
India based on English common law; limited judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations

 
Indonesia based on Roman-Dutch law, substantially modified by indigenous concepts and by new criminal procedures code; has not accepted compulsory ICJ jurisdiction

 
Iran the Constitution codifies Islamic principles of government

 
Iraq based on Islamic law in special religious courts, civil law system elsewhere; has not accepted compulsory ICJ jurisdiction

 
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

 
Isle of Man English common law and Manx statute

 
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

 
Italy based on civil law system; appeals treated as new trials; judicial review under certain conditions in Constitutional Court; has not accepted compulsory ICJ jurisdiction

 
Jamaica based on English common law; has not accepted compulsory ICJ jurisdiction

 
Jan Mayen the laws of Norway, where applicable, apply

 
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

 
Jarvis Island the laws of the US, where applicable, apply

 
Jersey English law and local statute

 
Johnston Atoll the laws of the US, where applicable, apply

 
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

 
Juan de Nova Island the laws of France, where applicable, apply

 
Kazakhstan based on civil law system

 
Kenya based on Kenyan statutory law, Kenyan and 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

 
Kingman Reef the laws of the US, where applicable, apply

 
Kiribati NA

 
Korea, North 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

 
Korea, South combines elements of continental European civil law systems, Anglo-American law, and Chinese classical thought

 
Kuwait civil law system with Islamic law significant in personal matters; has not accepted compulsory ICJ jurisdiction

 
Kyrgyzstan based on civil law system

 
Laos based on traditional customs, French legal norms and procedures, and Socialist practice

 
Latvia based on civil law system

 
Lebanon mixture of Ottoman law, canon law, Napoleonic code, and civil law; no judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction

 
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

 
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

 
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

 
Liechtenstein local civil and penal codes; accepts compulsory ICJ jurisdiction, with reservations

 
Lithuania based on civil law system; legislative acts can be appealed to the constitutional court

 
Luxembourg based on civil law system; accepts compulsory ICJ jurisdiction

 
Macau based on Portuguese civil law system

 
Macedonia based on civil law system; judicial review of legislative acts

 
Madagascar based on French civil law system and traditional Malagasy law; has not accepted compulsory ICJ jurisdiction

 
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

 
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

 
Maldives based on Islamic law with admixtures of English common law primarily in commercial matters; has not accepted compulsory ICJ jurisdiction

 
Mali based on French civil law system and customary law; judicial review of legislative acts in Constitutional Court (which was formally established on 9 March 1994); has not accepted compulsory ICJ jurisdiction

 
Malta based on English common law and Roman civil law; accepts compulsory ICJ jurisdiction, with reservations

 
Marshall Islands based on adapted Trust Territory laws, acts of the legislature, municipal, common, and customary laws

 
Martinique French legal system

 
Mauritania a combination of Shari'a (Islamic law) and French civil law

 
Mauritius based on French civil law system with elements of English common law in certain areas

 
Mayotte French law

 
Mexico mixture of US constitutional theory and civil law system; judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations

 
Micronesia, Federated States of based on adapted Trust Territory laws, acts of the legislature, municipal, common, and customary laws

 
Midway Islands the laws of the US, where applicable, apply

 
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 (OSCE) documents

 
Monaco based on French law; has not accepted compulsory ICJ jurisdiction

 
Mongolia blend of Russian, Chinese, Turkish, and Western systems of law that combines aspects of a parliamentary system with some aspects of a presidential system; constitution ambiguous on judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction

 
Montenegro based on civil law system