Legal system In 36 editions of 36.

varies by individual country; 186 (not including Yugoslavia) are parties to the UN 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; recently modified to accommodate political pluralism and increased use of free markets

NA

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; does not accept compulsory ICJ jurisdiction

derived from the legal system of Portugal

based on French civil law system, with common law influence; does not accept compulsory ICJ jurisdiction

based on French law

based on French civil law system and Chadian customary law; does not accept 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

partly based on Spanish civil law and tribal custom

NA

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

NA

NA

• 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

NA

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

NA

NA

• based on 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

• 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 Court (which was formally established on 9 March 1994);
• has not accepted compulsory ICJ jurisdiction

three-tier system:

Islamic (Shari'a) courts, special courts, and state security courts (in the process of being eliminated)

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 1990 constitution

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

based on English common law, Islamic law, 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 legal system and customary law; has not accepted compulsory ICJ jurisdiction

• based on French civil law system;
• judicial review of legislative acts in Constitutional Court;
• the Council of State audits the government's accounting office;
• Senegal 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

NA

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

• based on English common law and Islamic law;
• as of 20 January 1991, the now defunct Revolutionary Command Council imposed Islamic law in the northern states;
• Islamic law applies to all residents of the northern states regardless of their religion;
• 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

NA

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

• in 1995, the government restored the legal system to one based on English common law and customary law and reinstituted 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

US law, including certain criminal offenses by or against US nationals, such as murder, may apply to areas not under jurisdiction of other countries. 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 or scientific 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 Departments of Treasury, Commerce, Transportation, and Interior share enforcement responsibilities. Public Law 95-541, the US Antarctic Conservation Act of 1978, 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 (703) 306-1031.

NA

NA

NA

NA

Danish

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

NA

NA

a new legal system has not been adopted but all factions tacitly agree they will follow Shari'a (Islamic law)

based on civil law system

based on civil law system

based on English common law

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

NA

• 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 civil law system

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

• 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

based on civil law system

• 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

based on civil law system

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 status as an Islamic state; accepts compulsory ICJ jurisdiction, with reservations

based on civil law system; judicial review of legislative acts

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

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

based on civil law system

evolution of Soviet civil law; still lacks independent judicial system

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

note: Legislative Assembly passed landmark judicial reforms in 1996

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

NA

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 Spanish civil code

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 laws

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 the Constitutional Court;
• separate administrative and civil/penal supreme courts;
• has not accepted compulsory ICJ jurisdiction

based on civil law system

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

based on civil law system

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

based on civil law system

• 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

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

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

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

English law

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

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

NA

in process of revision, moving toward rule of law based on Western model

• 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;
• appeals treated as trials de novo;
• judicial review under certain conditions in Constitutional Court;
• has not accepted compulsory ICJ jurisdiction

English law and local statute

based on civil law system

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

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

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 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 OSCE documents

based on French law; has not accepted compulsory ICJ jurisdiction

• civil law system incorporating French penal theory;
• constitution does not permit judicial review of acts of the States General;
• accepts compulsory ICJ jurisdiction, with reservations

based on civil law system; judicial review of legislative acts

• 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 holdover communist legal theory;
• changes being gradually introduced as part of broader democratization process;
• limited judicial review of legislative acts although under the new constitution, the Constitutional Tribunal ruling will become final as of October 1999;
• court decisions can be appealed to the European Court of Justice in Strasbourg

• 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; is now based on the Constitution of France's Fifth Republic

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

based on civil law system

• civil law system based on Austro-Hungarian codes;
• has not accepted compulsory ICJ jurisdiction;
• legal code modified to comply with the obligations of Organization on Security and Cooperation in Europe (OSCE) and to expunge Marxist-Leninist legal theory

based on civil law system

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

based on civil law system; judicial review of legislative acts

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

based on Islamic law and English common law

based on common law, with civil law modifications

the 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