List of national legal systems
The contemporary legal systems of the world are generally based on one of three basic systems: civil law, common law, and religious law, or combinations of these. However, the legal system of each country is shaped by its unique history and so incorporates individual variations.
Civil law is the most widespread system of law around the world. It is also sometimes known as Continental European law. The central source of law that is recognized as authoritative is codifications in a constitution or statute passed by legislature, to amend a code.
While the concept of codification dates back to the Code of Hammurabi in Babylon ca. 1790 BC, civil law systems derive from the Roman Empire and, more particularly, the Corpus Juris Civilis issued by the Emperor Justinian ca. AD 529. This was an extensive reform of the law in the Byzantine Empire, bringing it together into codified documents. Civil law was also partly influenced by religious laws such as Canon law and Islamic law. Civil law today, in theory, is interpreted rather than developed or made by judges. Only legislative enactments (rather than legal precedents, as in common law) are considered legally binding.
- French civil law: in France, the Benelux countries, Italy, Romania, Spain and former colonies of those countries;
- German civil law: in Germany, Austria, Switzerland, Estonia, Latvia, former Yugoslav republics, Greece, Portugal and its former colonies, Turkey, Japan, and the Republic of China;
- Scandinavian civil law: in Denmark, Norway and Sweden. As historically integrated in the Scandinavian cultural sphere, Finland and Iceland also inherited the system.
- Chinese law: a mixture of civil law and socialist law in use in the People's Republic of China.
However, some of these legal systems are often and more correctly said to be of hybrid nature:
- Napoleonic to Germanistic influence (Italian civil law)
The Italian civil 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 including the Netherlands (1992), Argentina (2014), Brazil (2002) and Portugal (1966). Most of them have innovations introduced by the Italian legislation, including the unification of the civil and commercial codes.
- Germanistic to Napoleonic influence (Swiss civil law)
The Swiss civil code is considered mainly influenced by the German civil code and partly influenced by the French civil code. The civil code of the Republic of Turkey is a slightly modified version of the Swiss code, adopted in 1926 during Mustafa 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 a codified civil law follows:
|23x15px Albania||The Civil Code of the Republic of Albania, 1991 |
|23x15px Angola||Based on Portuguese civil law|
|23x15px Argentina||The Spanish legal tradition had a great influence on the Civil Code of Argentina, basically a work of the Argentine jurist Dalmacio Vélez Sársfield, who dedicated five years of his life on 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, the Draft of the Spanish Civil Code of 1851, the Napoleonic code and the Chilean 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 a Paraguayan law of 1880, until the new Civil Code went in force in 1987.
During the second half of the 20th century, the German legal theory became increasingly influential in Argentina.
|23x15px Andorra||Courts apply the customary laws of Andorra, supplemented with Roman law and customary Catalan law.|
|23x15px Armenia||The Legal System of Armenia|
|23x15px Aruba||Based on Dutch civil law|
|23x15px Austria||The Allgemeines bürgerliches Gesetzbuch (ABGB) of 1811|
|23x15px Azerbaijan||Based on German, French, Russian and traditional Azerbaijani Law|
|23x15px Belgium||The Napoleonic Code is still in use, although it is heavily modified (especially concerning family law)|
|23x15px Bolivia||Influenced by the Napoleonic Code|
|23x15px Bosnia and Herzegovina||Influenced by Austrian law. The Swiss civil law (Zivilgesetzbuch) was a model for the Law on Obligations of 1978.|
|23x15px Brazil||Based on Portuguese civil law|
|23x15px Bulgaria||Civil Law system influenced by Germanic and Roman law systems|
|23x15px Burkina Faso|
|23x15px People's Republic of China||Civil law system; based on native customs and practices with Soviet and German influence|
|23x15px Republic of the Congo|
|23x15px Democratic Republic of the Congo||Based on Belgian civil law|
|23x15px Cote d'Ivoire|
|23x15px Cape Verde||Based on Portuguese civil law|
|23x15px Central African Republic|
|23x15px Chile||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 other Latin-American states. 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 the Civil Code of Chile, Venezuelan Andrés Bello, worked for its completion for almost 30 years, using elements, of the Spanish law on the one hand, and of other Western laws, especially of the French one, on the other. Indeed, it is noted that he consulted and used all of the codes that had been issued till then, starting from the era of Justinian.
The Civil Code came into effect on 1 January 1857. The influence of the Napoleonic code and the Law of Castile of the spanish colonial period (especially the Siete Partidas), is great; it is observed however that e.g. in many provisions of property or contract law, the solutions of the French code civil were put aside in favor of pure Roman law or Castilian law.
|23x15px Colombia||Civil code introduced in 1873. Nearly faithful reproduction of the Chilean civil code|
|23x15px Costa Rica||First Civil Code (a part of the General Code or Carrillo Code) came into effect in 1841; its text was inspired by the South Peruvian Civil Code of Marshal Andres de Santa Cruz. The present Civil Code went into effect 1 January 1888, and was influenced by the Napoleonic Code and the Spanish Civil Code of 1889 (from its 1851 draft version).|
|23x15px Croatia||Influenced by Austrian and Hungarian law. The Law on Obligations of 2005.|
|23x15px Cuba||Influenced by Spanish and American law with large elements of Communist legal theory.|
|23x15px Curaçao||Based on Dutch Cival Law.|
|23x15px Czech Republic||Descended from the Civil 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 of socialist law after the Velvet Revolution (1989).|
|23x15px Denmark||Scandinavian-German civil law|
|23x15px Dominican Republic||Based by the Napoleonic Code|
|23x15px Ecuador||Civil code introduced in 1861. Nearly faithful reproduction of the Chilean civil code|
|23x15px El Salvador|
|23x15px Estonia||Largely influenced by German civil law.|
|23x15px Finland||Civil law system based on Swedish law|
|23x15px France||Based on the Napoleonic code (code civil of 1804)|
|23x15px Equatorial Guinea|
|23x15px Guinea||Based on French civil law system, customary law, and decree|
|23x15px Guinea-Bissau||Based on Portuguese civil law|
|23x15px Germany||The Bürgerliches Gesetzbuch of 1900 ("BGB"). The BGB is influenced both by Roman and German law traditions.|
|23x15px Greece||The Greek civil code of 1946, highly influenced by traditional Roman law and the German civil code of 1900 (Bürgerliches Gesetzbuch); the Greek civil code replaced the Byzantine–Roman civil law in 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')|
|23x15px Guatemala||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 which 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 de Amparo', and the Supreme Court acting as a 'Tribunal de Casación') whose theses become binding for lower courts.
|Template:Country data Haiti Haiti||Influenced by the Napoleonic Code|
|Template:Country data Honduras Honduras|
|23x15px Hungary||Based on codified Roman law, with elements of the Napoleonic civil code|
|Template:Country data Iceland Iceland||Based on Germanic traditional laws and influenced by Medieval Norwegian and Danish laws.|
|23x15px Italy||Based on codified Roman law, with elements of the Napoleonic civil code; civil code of 1942 replaced the original one of 1865|
|Template:Country data Japan Japan||Modeled after European (primarily German) civil law system. Japanese civil code of 1895.|
|23x15px Latvia||Based on codified Roman law with strong German traditions in civil and administrative law and procedure, as it was historically before the Soviet occupation, elements of French legal system are also common in Latvian law. While general principles of law are prerequisites in making and understanding the law, case law is also broadly applied to present legal arguments in courts and to explain application of law in similar cases. Rapidly decreasing remains of Soviet understanding of criminal acts can be found in criminal law, while criminal procedure law has been fully modeled after practice accepted in Western Europe. Civil law of Latvia enacted on 1937.|
|23x15px Lebanon||Modeled after French civil law|
|23x15px Lithuania||Modeled after Dutch civil law|
|23x15px Luxembourg||Influenced by the Napoleonic Code|
|23x15px Libya||Influenced by Ottoman, French, Italian, and Egyptian sources|
|23x15px Macau||Based on the Portuguese strand of the continental tradition, itself much influenced by Germany; also influenced by the law of the PRC|
|23x15px Mexico||"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) ..."|
|23x15px Mongolia||Civil Code of 2002 based on German BGB|
|23x15px Montenegro||First: the General Property Code for the Principality of Montenegro of 1888, written by Valtazar Bogišić. Present: the Law on Obligations of 2008.|
|23x15px Mozambique||Based on Portuguese civil law|
|23x15px Netherlands||Influenced by the Napoleonic Code|
|23x15px Norway||Scandinavian-German civil law. King Magnus VI the Lawmender unified the regional laws into a single code of law for the whole kingdom in 1274. This was replaced by Christian V's Norwegian Code of 1687.|
|23x15px Paraguay||The Paraguayan Civil Code in force since 1987 is largely influenced by the Napoleonic Code and the Argentinian Code|
|23x15px Peru||Based on civil law system; accepts compulsory ICJ jurisdiction with reservations|
|23x15px Poland||The Polish Civil Code in force since 1965|
|23x15px Portugal||Influenced by the Napoleonic Code and later by the German Civil Law|
|23x15px Republic of China (Taiwan)||Codification derived from German BGB.|
|23x15px Romania||Civil Code came 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)|
|23x15px Russia||Civil Law system descendant from Roman Law through Byzantine tradition. Heavily influenced by German and Dutch norms in 1700–1800s. Socialist-style modification in 1900s, and Continental European Law influences since 1990s.|
|23x15px São Tomé e Príncipe||Based on Portuguese civil law|
|23x15px Serbia||First: the Civil Code of Principality of Serbia of 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.|
|23x15px Slovakia||Descended from the Civil 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 of socialist law after the Velvet Revolution (1989).|
|23x15px Slovenia||A Civil Law system influenced mostly by Germanic and Austro-Hungarian law systems|
|23x15px Spain||Influenced by the Napoleonic Code, it also has some elements of Spain's legal tradition, starting with the Siete Partidas, a 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.|
|23x15px Sweden||Scandinavian-German 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 is indeed worth mentioning that it assimilated very few elements of foreign laws whatsoever. It is also interesting that the Napoleonic Code had no influence in codification of law in Scandinavia. The historical basis of the law of Sweden, just as for all Nordic countries, is Old German 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 the Code Civil or the BGB.|
|23x16px Switzerland||The Swiss Civil Code of 1908 and 1912 (obligations; fifth book)|
|23x15px Timor-Leste||Based on Portuguese civil law|
|23x15px Turkey||Modeled after the Swiss civil law (Zivilgesetzbuch) of 1907.|
|23x15px Ukraine||Civil Code of Ukraine of 2004|
|23x15px Uzbekistan||Represents an evolution of Soviet civil law. Overwhelmingly strong impact of the Communist legal theory is traceable.|
|23x15px Vietnam||Communist legal theory and French civil law|
|23x15px Venezuela||Civil law|
Common law and equity are systems of law whose sources are the decisions in cases by judges. Alongside, 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. Statutes were allowed to be made by the government. Common law developed in England, influenced by Anglo-Saxon law and to a much lesser extent by the Norman conquest of England, which introduced legal concepts from Norman law, which, in turn, had its origins in Salic law. Common law was later inherited by the Commonwealth of Nations, and almost every former colony of the British Empire has adopted it (Malta being an exception). The doctrine of stare decisis, also known as case law or precedent by courts, is the major difference to codified civil law systems.
Common law is currently in practice in Ireland, most of the United Kingdom (England and Wales and Northern Ireland), Australia, New Zealand, Bangladesh, India (excluding Goa), Pakistan, South Africa, Canada (excluding Quebec), Hong Kong, the United States, on a state level, (excluding Louisiana) and many other places. In addition to these countries, several others have adapted the common law system into a mixed system. For example, Nigeria operates largely on a common law system, but incorporates religious law.
In the European Union, the Court of Justice takes 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 English Magna 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.
|23x15px American Samoa||Based on law of the United States|
|23x15px Antigua and Barbuda||Based on English common law|
|23x15px Australia||Based on English common law|
|23x15px Bahamas||Based on English common law|
|23x15px Bangladesh||Based on English common law|
|23x15px Barbados||Based on English common law|
|23x15px Belize||Based on English common law|
|23x15px British Virgin Islands||Based on English common law|
|23x15px Canada||Based on English common law, except in 23x15px Quebec, where a civil law system based on French law prevails 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 bijuridical nature of Canada and use both common law and civil law terms where appropriate.|
|23x15px Cyprus||Based on English common law as inherited from British colonisation, with civil law influences, particularly in criminal law.|
|23x15px Dominica||Based on English common law|
| 23x15px 23x15px England and Wales
|Primarily common law, with early Roman and some modern continental European influences|
|23x15px Fiji||Based on English common law|
|23x15px Gibraltar||Based on English common law|
|23x15px Grenada||Based on English common law|
|Template:Country data Hong Kong Hong Kong||Principally based on English common law|
|Template:Country data India India||Based on English common law (except Goa, Daman and Diu which follow a Civil Law based on Portuguese Civil Law|
|Template:Country data Republic of Ireland Ireland||Based on Irish law before 1922, which was itself based on English common law|
|Template:Country data Israel Israel||Based on English common law from the period of the British Mandate (that includes laws from Ottoman Empire time), also incorporating civil law and fragments of Halakha and Sharia for family law cases|
|Template:Country data Jamaica Jamaica||Based on English common law|
|Template:Country data Kiribati Kiribati||Based on English common law|
|23x15px Liberia||Based on Anglo-American and customary law|
|23x15px Marshall Islands||Based on law of the United States|
|23x15px Myanmar||Based on English common law|
|23x15px Nauru||Based on English common law|
|23x15px New Zealand||Based on English common law|
| Northern Ireland
|Based on Irish law before 1921, in turn based on English common law|
|23x15px Palau||Based on law of the United States|
|23x15px Pakistan||Based on English common law with some provisions of Islamic law|
|23x15px Saint Kitts and Nevis||Based on English common law|
|23x15px Saint Vincent and the Grenadines||Based on English common law|
|23x15px Singapore||Based on English common law, but Muslims are subject to the Administration of Muslim Law Act, which gives the Sharia Court jurisdiction over Muslim personal law, e.g., marriage, inheritance and divorce.|
|23x15px Tonga||Based on English common law|
|23x15px Trinidad and Tobago||Based on English common law|
|23x15px Tuvalu||Based on English common law|
|23x15px Uganda||Based on English common law|
|23x15px United States|| Federal courts and 50 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 first impression and rarely, if ever, look at contemporary cases on the same issue in the UK or the Commonwealth.|
State law in the U.S. state of Louisiana is based on French and Spanish civil law (see above)
Religious and sharia 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 Jewish and Halakha for public law has a static and unalterable quality, precluding amendment through legislative acts of government or development through judicial precedent; Christian Canon law is more similar to civil law in its use of civil codes; and Islamic Sharia law (and Fiqh jurisprudence) is based on legal precedent and reasoning by analogy (Qiyas), and is thus considered similar to common law.
The main kinds of religious law are Sharia in Islam, Halakha in Judaism, and canon law in 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 the Middle Ages.
The Islamic legal system of Sharia (Islamic law) and Fiqh (Islamic jurisprudence) is the most widely used religious law, and one of the three most common legal systems in the world alongside common law and civil law. It is based on both divine law, derived from the Qur'an and Sunnah, and the rulings of Ulema (jurists), who used the methods of Ijma (consensus), Qiyas (analogical deduction), Ijtihad (research) and Urf (common practice) to derive Fatwā (legal opinions). An Ulema was required to qualify for an Ijazah (legal doctorate) at a Madrasa (law school/college) before they could issue Fatwā. During the Islamic Golden Age, classical Islamic law may have had an influence on the development of common law and 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 or public law.
The Halakha is followed by orthodox and conservative Jews in both ecclesiastical and civil relations. No country is fully governed by Halakha, 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 law is 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 law regulates the internal ordering of the Catholic Church, the Eastern Orthodox Church and the Anglican Communion. Canon law is amended and adapted by the legislative authority of the church, such as councils of bishops, single bishops for their respective sees, the Pope for the entire Catholic Church, and the British Parliament for the Church of England.
|23x15px Afghanistan||Islamic law & American/British law after invasion|
|23x15px Egypt||Islamic law is ensured in Article 2 of the Egyptian constitution.|
|23x15px The Gambia||English common law, Islamic law and customary law|
|23x15px Ghana||Based on English common law|
|Template:Country data Iran Iran||Shia Islamic law|
|23x15px Libya||Islamic law|
|23x15px Mauritania||mix of Islamic law and French Civil Codes, Islamic law largely applicable to family law.|
|23x15px Morocco||mix of Islamic law and French Civil Codes, Islamic law largely applicable to family law.|
|23x15px Nigeria||Sharia in the northern states, common law in the south and at the federal level.|
|23x15px Oman||Sharia and tribal custom laws|
|23x15px Saudi Arabia||Islamic law|
|23x15px Sudan||Based on Islamic law|
|23x16px Vatican City||Based on principles of Italian and canonical law|
|23x15px Yemen||Islamic law|
Civil law and common law
|23x15px Botswana||Based on South African law. An 1891 proclamation by the High Commissioner for Southern Africa applied the law of the Cape Colony (now part of South Africa) to the Bechuanaland Protectorate (now Botswana).|
|23x15px 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 Orthodox canon law, Muslim religious law, and Ottoman civil law.|
|23x15pxJersey||The Bailiwick of Jersey's legal system draws on local legislation enacted by the States of Jersey, Norman customary law, English common law and modern French civil law|
|23x15px Lesotho||Based on South African law. An 1884 proclamation by the High Commissioner for Southern Africa applied the law of the Cape Colony (now part of South Africa) to Basutoland (now Lesotho).|
| 23x15px Louisiana
|Based on French and Spanish civil law, but federal laws (based on common law) are also in effect in Louisiana because of federal Supremacy Clause.|
|23x15px Malta||Initially based on Roman Law and eventually progressed to the Code de Rohan, the Napoleonic Code with influences from Italian Civil Law. English common law however is also a source of Maltese Law, most notably in Public Law|
|23x15px Namibia||Based on South African law. South Africa conquered South-West Africa (now Namibia) in 1915, and a 1919 proclamation by the Governor-General applied the law of the Cape Province of South Africa to the territory.|
|23x15px Philippines||Based on Spanish law; influenced by U.S. common law after 1898 Spanish– and Philippine–American Wars, personal law based on sharia law applies to Muslims|
| 23x15px Puerto Rico
|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.|
| 23x15px Quebec
|After the 1763 Treaty of Paris awarded French Canada to Great Britain, the British initially attempted to impose English Common Law, but in response to the deteriorating political situation in the nearby Thirteen Colonies, the Quebec Act was passed in 1774, which allowed a mix of English Common Law and customary civil law, based on the Coutume de Paris. Codification occurred in 1866 with the enactment of the Civil Code of Lower Canada, which continued in force when the modern Province of Quebec was created at Confederation in 1867. Canadian federal law in force in Quebec is based on common law, but federal statutes also take into account the bijuridical nature of Canada and use both common law and civil law terms where appropriate.|
|23x15px Saint Lucia|
| 23x15px Scotland
|Based on Roman and continental law, with common law elements dating back to the High Middle Ages.|
|23x15px 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. See Seychelles Legal Environment.|
|23x15px South Africa||An amalgam of Roman-Dutch civil law and English common law, as well as Customary Law.|
|23x15px Sri Lanka||An amalgam of English common law, Roman-Dutch civil law and Customary Law|
|23x15px Swaziland||Based on South African law. A 1907 proclamation by the High Commissioner for Southern Africa applied the Roman-Dutch common law of the Transvaal Colony (now part of South Africa) to Swaziland.|
|23x15px Thailand||The Thai legal system became an amalgam of German, Swiss, French, English, Japanese, Italian, and Indian 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.|
|23x15px Vanuatu||Consists of a mixed system combining the legacy of English common law, French civil law and indigenous customary law.|
|23x15px Zimbabwe||Based on South African law. An 1891 proclamation by the High Commissioner for Southern Africa applied the law of the Cape Colony (now part of South Africa) to Southern Rhodesia (now Zimbabwe).|
Civil law and sharia law
|23x15px Egypt||Family Law (personal Statute) for Muslims based on Islamic Jurisprudence, Seaerate Personal Statute for non Muslims, and all other branches of Law are based on French civil law system|
|Template:Country data Indonesia Indonesia||Based on civil law of Holland and adat (cultural law of Indonesia)|
|Template:Country data Jordan Jordan||Mainly based on French Civil Code and Ottoman Majalla, Islamic law applicable to family law|
|23x15px Morocco||Based on Islamic law and French and Spanish civil law system|
|23x15px Qatar||Based on Islamic law and Egyptian civil law system (after the French civil law system)|
|23x15px Syria||Based on Islamic law and French civil law system|
|23x15px United Arab Emirates||Based on Islamic law and Egyptian civil law system (after the French civil law system)|
Common law and sharia law
|23x15px Bangladesh||Common law, personal law based on sharia law applies to Muslims|
|23x15px Malaysia||Based on English common law, personal law based on sharia law applies to Muslims|
|23x15px Nigeria||Sharia is applied in some northern states|
|23x15px Pakistan||Based on English Common Law, some Islamic law applications in inheritance. Tribal Law in FATA|
|Template:Country data India India||The most prominent example of a hybrid legal system is the Indian legal system. India follows a mixture of civil, common law and customary or religious law. Separate personal law codes apply to Muslims, Christians, and Hindus. Decisions by the Supreme Court of India and High Courts are binding on the lower courts. Further, most of the laws are statutory and it also has a constitution which signifies the Civil nature of law in India.|
Systems by geography
Despite the usefulness of different classifications, every legal system has its own individual identity. Below are groups of legal systems, categorised by their geography. Click the "show" buttons on the right for the lists of countries.
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- This definition is partly disputed - Thomson, Stephen, Mixed Jurisdiction and the Scottish Legal Tradition: Reconsidering the Concept of Mixture (2014) 7(1) Journal of Civil Law Studies 51-91
- Moustaira Elina N., Comparative Law: University Courses (in Greek), Ant. N. Sakkoulas Publishers, Athens, 2004, ISBN 960-15-1267-5
- Moustaira Elina N., Milestones in the Course of Comparative Law: Thesis and Antithesis (in Greek), Ant. N. Sakkoulas Publishers, Athens, 2003, ISBN 960-15-1097-4