Legal system In 36 editions of 36.

varies among each of the entities; 162 are parties to the United Nations International Court of Justice (ICJ) or World Court

• 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

based on Portuguese civil law system and customary law, but being modified along socialist lines

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

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

based on French civil law system and customary law

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

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

based on French law

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

French and Muslim law in a new consolidated code

based on Belgian civil law system and tribal law; has not accepted compulsory ICJ jurisdiction

based on French civil law system and customary law

• 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

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

• 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

in transition; partly based on Spanish civil law and tribal custom

• based on South African Roman-Dutch law in statutory courts, Swazi traditional law and custom in traditional courts;
• has not accepted compulsory ICJ jurisdiction

complex structure with civil, Islamic, common, and customary law influences; has not accepted compulsory ICJ jurisdiction

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

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

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

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

NA

• based on English common law, tribal law, and Islamic law;
• judicial review in High Court;
• accepts compulsory ICJ jurisdiction, with reservations;
• constitutional amendment in 1982 made Kenya a de jure one-party state

• 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

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

• 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

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

• 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

• based on French civil law system and customary law;
• judicial review of legislative acts in Constitutional Section of Court of State;
• has not accepted compulsory ICJ jurisdiction

based on Islamic law

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

French law

based on Islamic law and French and Spanish civil law system; judicial review of legislative acts in Constitutional Chamber of Supreme Court

based on Portuguese civil law system and customary law

based on Roman-Dutch law and customary law

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

based on English common law, Islamic, and tribal law

French law

• based on German and Belgian civil law systems and customary law;
• judicial review of legislative acts in the Supreme Court;
• has not accepted compulsory ICJ jurisdiction

NA

based on Portuguese law system and customary law; has not accepted compulsory ICJ jurisdiction

• based on French civil law system;
• judicial review of legislative acts in Supreme Court, which also audits the government's accounting office;
• has not accepted compulsory ICJ jurisdiction

based on English common law, French civil law, and customary law

based on English law and customary laws indigenous to local tribes; has not accepted compulsory ICJ jurisdiction

based on Roman-Dutch law and English common law; accepts compulsory ICJ jurisdiction, with reservations

• based on English common law and Islamic law;
• in September 1983 then President Nimeiri declared the penal code would conform to Islamic law;
• some separate religious courts;
• accepts compulsory ICJ jurisdiction, with reservations

• based on English common law;
• judicial review of legislative acts limited to matters of interpretation;
• has not accepted compulsory ICJ jurisdiction

French-based court system

based on French civil law system and Islamic law; some judicial review of legislative acts in the Supreme Court in joint session

• government plans to restore system based on English common law and customary law and reinstitute a normal judicial system;
• accepts compulsory ICJ jurisdiction, with reservations

• based on English common law and customary law;
• judicial review of legislative acts in an ad hoc constitutional council;
• has not accepted compulsory ICJ jurisdiction

mixture of Roman-Dutch and English common law

English common law

Danish

civil law system based on Danish law; does not accept compulsory ICJ jurisdiction

has not accepted compulsory ICJ jurisdiction

based on English common law

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

• 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

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

• civil law system with English-American influence;
• judicial review of legislative acts in the Supreme Court;
• accepts compulsory ICJ jurisdiction, with reservations

• 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

combines elements of continental European civil law systems, Anglo-American law, and Chinese classical thought; has not accepted compulsory ICJ jurisdiction

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

• blend of Russian, Chinese, and Turkish systems of law;
• no constitutional provision for judicial review of legislative acts;
• has not accepted compulsory ICJ jurisdiction

based on Hindu legal concepts and English common law; has not accepted compulsory ICJ jurisdiction

based on English common law with provisions to accommodate Pakistan's stature as an Islamic state; accepts compulsory ICJ jurisdiction, with reservations

a highly complex mixture of English common law, Roman-Dutch, Muslim, and customary law; has not accepted compulsory ICJ jurisdiction

based on English common law

based on English common law

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

based on English common law

English common law; no judicial review of legislative acts

English law

English law

British common law and local statutes

• based on Spanish civil law system;
• judicial review of legislative acts in the Supreme Court;
• has not accepted compulsory ICJ jurisdiction

based on Spanish and American law, with large elements of Communist legal theory; does not accept compulsory ICJ jurisdiction

based on English common law

based on French civil codes

• 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

based on English common law

French legal system

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

based on Roman civil law system; accepts compulsory ICJ jurisdiction

• rooted in Roman and Spanish civil law;
• some influence of English common law;
• accepts ICJ jurisdiction, with reservations

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

French legal system

English common law and statute law

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

civil law system; Supreme Court may review administrative acts

• based on civil law system;
• judicial review of legislative acts in the Supreme Court of Justice;
• accepts compulsory ICJ jurisdiction, with reservations

based on English common law

based on English common law

based on English common law

based on English common law

• based on English common law;
• judicial review of legislative acts in the Supreme Court;
• has not accepted compulsory ICJ jurisdiction

based on laws of England and Wales with a small number adopted from Jamaica and The Bahamas

based on US

judicial review of legislative acts only in the Presidium of the People's Assembly, which is not a true court; has not accepted compulsory ICJ jurisdiction

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

• civil law system with Roman law origin;
• judicial review of legislative acts by a Constitutional Court;
• separate administrative and civil/penal supreme courts;
• has not accepted compulsory ICJ jurisdiction

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

• based on civil law system, with Soviet law influence;
• judicial review of legislative acts in the State Council;
• has accepted compulsory ICJ jurisdiction

• civil law system based on Austro-Hungarian codes, modified by Communist legal theory;
• no judicial review of legislative acts;
• has not accepted compulsory ICJ jurisdiction

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

Danish

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

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

• civil law system modified by Communist legal theory;
• no judicial review of legislative acts;
• has not accepted compulsory ICJ jurisdiction

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

English law

NA

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

• based on Communist legal theory, with both civil law system (civil code of 1960) and common law elements;
• Supreme Court renders decisions of principle that sometimes have the effect of declaring legislative acts unconstitutional;
• has not accepted compulsory ICJ jurisdiction

• based on English common law, substantially modified by indigenous concepts;
• judicial review of legislative acts in Supreme Court;
• has not accepted compulsory ICJ jurisdiction

English law and local statute

• based on civil law system, with ecclesiastical law influence;
• judicial review under certain conditions in Constitutional Court;
• has not accepted compulsory ICJ jurisdiction

English law and local statute

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

based on civil law system; accepts compulsory ICJ jurisdiction

based on English common law and Roman civil law; has accepted compulsory ICJ jurisdiction, with reservations

based on French law; has not accepted compulsory ICJ jurisdiction

• civil law system incorporating French penal theory;
• judicial review in the Supreme Court of legislation of lower order rather than Acts of Parliament;
• accepts compulsory ICJ jurisdiction, with reservations

• mixture of customary law, civil law system, and common law traditions;
• Supreme Court renders advisory opinions to legislature when asked;
• accepts compulsory ICJ jurisdiction, with reservations

• mixture of Continental (Napoleonic) civil law and Communist legal theory;
• no judicial review of legislative acts;
• has not accepted compulsory ICJ jurisdiction

• civil law system;
• the Constitutional Tribunal reviews the constitutionality of legislation;
• accepts compulsory ICJ jurisdiction, with reservations

• former mixture of civil law system and Communist legal theory that increasingly reflected Romanian traditions is being revised;
• Communist regime had not accepted compulsory ICJ jurisdiction;
• Provisional Council of National Unity will probably accept ICJ jurisdiction

based on civil law system with Italian law influences; has not accepted compulsory ICJ jurisdiction

• civil law system as modified by Communist legal theory;
• no judicial review of legislative acts;
• has not accepted compulsory ICJ jurisdiction

civil law system, with regional applications; does not accept compulsory ICJ jurisdiction

civil law system influenced by customary law; accepts compulsory ICJ jurisdiction, with reservations

• civil law system influenced by customary law;
• judicial review of legislative acts, except with respect to federal decrees of general obligatory character;
• accepts compulsory ICJ jurisdiction, with reservations

• common law tradition with early Roman and modern continental influences;
• no judicial review of Acts of Parliament;
• accepts compulsory ICJ jurisdiction, with reservations

mixture of civil law system and Communist legal theory; has not accepted compulsory ICJ jurisdiction

based on Islamic law and English common law

based on common law, with civil law modifications

the new Constitution codifies Islamic principles of government

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

• 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

• based on Islamic law and French codes;
• judicial review of legislative acts in a specially provided High Tribunal;
• has not accepted compulsory ICJ jurisdiction

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

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

• based on English common law and Islamic law;
• ultimate appeal to the sultan;
• has not accepted compulsory ICJ jurisdiction

discretionary system of law controlled by the amir, although civil codes are being implemented; Islamic law is significant in personal matters

• based on Islamic law, several secular codes have been introduced;
• commercial disputes handled by special committees;
• has not accepted compulsory ICJ jurisdiction

• based on Islamic law and civil law system;
• special religious courts;
• has not accepted compulsory ICJ jurisdiction

derived from various continental legal systems; accepts compulsory ICJ jurisdiction, with reservations

secular codes are being introduced by the UAE Government and in several member shaykhdoms; Islamic law remains influential

based on Turkish law, Islamic law, and local customary law; has not accepted compulsory ICJ jurisdiction

based on Islamic law (for personal matters) and English common law (for commercial matters)

English law

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

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

French law

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

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

based on British system

based on French system

NA

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

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

own Acts of Parliament and British common law

the 1988 Matignon Accords grant substantial autonomy to the islands; formerly under French law

• based on English law,
• with special land legislation and land courts for Maoris;
• accepts compulsory ICJ jurisdiction,
• with reservations

English common law

wide legislative and executive responsibility under the Norfolk Island Act of 1979; Supreme Court

NA

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

based on English common law

local island by-laws

• based on English common law and local customs;
• judicial review of legislative acts with respect to fundamental rights of the citizen;
• has not accepted compulsory ICJ jurisdiction

common law

British and local statutes