Legal system In 36 editions of 36.

all members of the UN plus Switzerland are parties to the statute that established the 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

• the laws of France,
• where applicable,
• apply

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

derived from the legal system of Portugal

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

partly based on Spanish civil law and tribal custom

operates on the basis of transitional laws that incorporate pre-independence statutes of the Eritrean People's Liberation Front, revised Ethiopian laws, customary laws, and post independence enacted laws

• 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

currently transitional mix of national and regional courts

• the laws of France,
• where applicable,
• apply

• 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

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

• the laws of France,
• where applicable,
• apply

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

NA

• the laws of France,
• where applicable,
• apply

• 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

a combination of Shari'a (Islamic law) and French civil 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 1990 constitution

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

based on English common law, Islamic Shariah law (only in some northern states), and traditional 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;
• 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

• the laws of France,
• where applicable,
• apply

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; 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

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 see their website at www.nsf.gov.

• the laws of Norway,
• where applicable,
• apply

• the laws of France,
• where applicable,
• apply

• the laws of Australia,
• where applicable,
• apply

• the laws of the UK,
• where applicable,
• apply

Danish

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

• the laws of Norway,
• where applicable,
• apply

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

• the laws of the UK,
• where applicable,
• apply

• 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, 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

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 accepted compulsory ICJ jurisdiction

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

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

French legal system

English common law and statutory law

• the laws of the US,
• where applicable,
• apply

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

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 common law and Manx statute

• based on civil law system;
• appeals treated as new trials;
• 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; accepts 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 Organization for Security and Cooperation in Europe (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; has not accepted 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;
• British courts and legislation are increasingly subject to review by European Union courts

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