The CIA World Factbook Edition 2008 Government

Legal system In 36 editions of 36.

Legal system was published in 36 editions of the CIA World Factbook, from 1990 to 2025. The 2008 edition carries it in 250 entries, in its Government section. Every entry is shown as that edition published it.

entries in the 2008 edition: 250
the first edition with it: 1990
the latest edition with it: 2025

Published as “Legal system” (1990 to 2025).

the entry has the field in that editionnot in that editionthe open editionEach entry below ends in its editions with Legal system, 1990 to 2025. Point at a year above to follow it down; choose one in a row to read that edition’s text there.

Entries with Legal system in each edition

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World

1 entry

World

all members of the UN are parties to the statute that established the International Court of Justice (ICJ) or World Court

Africa

55 entries

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

Angola

based on Portuguese civil law system and customary law;
modified to accommodate political pluralism and increased use of free markets;
has not accepted compulsory ICJ jurisdiction

Benin

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

Botswana

based on Roman-Dutch law and local customary law;
judicial review limited to matters of interpretation;
accepts compulsory ICJ jurisdiction, with reservations

Burkina Faso

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

Burundi

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

Cape Verde now Cabo Verde

based on the legal system of Portugal; has not accepted compulsory ICJ jurisdiction

Cameroon

based on French civil law system, with common law influence; accepts compulsory ICJ jurisdiction

Central African Republic

based on French law; has not accepted compulsory ICJ jurisdiction

Chad

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

Comoros

French and Islamic law in a new consolidated code; has not accepted compulsory ICJ jurisdiction

Congo, Democratic Republic of the now Democratic Republic of the Congo

a new constitution was adopted by referendum 18 December 2005; accepts compulsory ICJ jurisdiction, with reservations

Congo, Republic of the now Republic of the Congo

based on French civil law system and customary law; has not 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;
accepts compulsory ICJ jurisdiction, with reservations

Djibouti

based on French civil law system, traditional practices, and Islamic law; accepts ICJ jurisdiction, with reservations

Egypt

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

Equatorial Guinea

partly based on Spanish civil law and tribal custom; has not accepted compulsory ICJ jurisdiction

Eritrea

primary basis is the Ethiopian legal code of 1957, with revisions;
new civil, commercial, and penal codes have not yet been promulgated;
government also issues unilateral proclamations setting laws and policies;
also relies on customary and post-independence-enacted laws and, for civil cases involving Muslims, Islamic law;
does not accept compulsory ICJ jurisdiction

Swaziland now Eswatini

based on South African Roman-Dutch law in statutory courts and Swazi traditional law and custom in traditional courts;
accepts compulsory ICJ jurisdiction with reservations

Ethiopia

based on civil law;
currently transitional mix of national and regional courts;
has not accepted compulsory ICJ jurisdiction

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 now The Gambia

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

Ghana

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

Guinea

based on French civil law system, customary law, and decree; accepts compulsory ICJ jurisdiction with reservations

Guinea-Bissau

based on French civil law; accepts compulsory ICJ jurisdiction

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

Lesotho

based on English common law and Roman-Dutch law;
judicial review of legislative acts in High Court and Court of Appeal;
accepts compulsory ICJ jurisdiction with reservations

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;
accepts compulsory ICJ jurisdiction with reservations

Libya

based on Italian and French civil law systems and Islamic law;
separate religious courts;
no constitutional provision for judicial review of legislative acts;
has not accepted compulsory ICJ jurisdiction

Madagascar

based on French civil law system and traditional Malagasy law; accepts compulsory ICJ jurisdiction with reservations

Malawi

based on English common law and customary law;
judicial review of legislative acts in the Supreme Court of Appeal;
accepts compulsory ICJ jurisdiction with reservations

Mali

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

Mauritania

a combination of Islamic law and French civil law; has not accepted compulsory ICJ jurisdiction

Mauritius

based on French civil law system with elements of English common law in certain areas; accepts compulsory ICJ jurisdiction with reservations

Mayotte

the laws of France,
where applicable,
apply

Morocco

based on Islamic law and French and Spanish civil law systems;
judicial review of legislative acts in Constitutional Chamber of Supreme Court;
has not accepted compulsory ICJ jurisdiction

Mozambique

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

Namibia

based on Roman-Dutch law and 1990 constitution; has not accepted compulsory ICJ jurisdiction

Niger

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

Nigeria

based on English common law, Islamic law (in 12 northern states), and traditional law; accepts compulsory ICJ jurisdiction with reservations

Rwanda

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

Saint Helena now Saint Helena, Ascension, and Tristan da Cunha

English common law and statutes, supplemented by local statutes

Sao Tome and Principe

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

Senegal

based on French civil law system;
judicial review of legislative acts in Constitutional Court;
the Council of State audits the government's accounting office;
accepts compulsory ICJ jurisdiction with reservations

Seychelles

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

Sierra Leone

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

Somalia

no national system;
a mixture of English common law, Italian law, Islamic Sharia, and Somali customary law;
accepts compulsory ICJ jurisdiction with reservations

South Africa

based on Roman-Dutch law and English common law; has not accepted compulsory ICJ jurisdiction

Sudan

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;
however, the CPA establishes some protections for non-Muslims in Khartoum;
some separate religious courts;
accepts compulsory ICJ jurisdiction with reservations;
the southern legal system is still developing under the CPA following the civil war;
Islamic law will not apply to the southern states

Tanzania

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

Togo

French-based court system; accepts compulsory ICJ jurisdiction, with reservations

Tunisia

based on French civil law system and Islamic law;
some judicial review of legislative acts in the Supreme Court in joint session;
has not accepted compulsory ICJ jurisdiction

Uganda

in 1995, the government restored the legal system to one based on English common law and customary law; accepts compulsory ICJ jurisdiction, with reservations

Zambia

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

Zimbabwe

mixture of Roman-Dutch and English common law; has not accepted compulsory ICJ jurisdiction

Antarctic Region

5 entries

Antarctica

Antarctica is administered through meetings of the consultative member nations;
decisions from these meetings are carried out by these member nations (with respect to their own nationals and operations) in accordance with their own national laws;
US law, including certain criminal offenses by or against US nationals, such as murder, may apply extraterritorially;
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, Room 5805, 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;
more generally, access to the Antarctic Treaty area, that is to all areas between 60 and 90 degrees south latitude, is subject to a number of relevant legal instruments and authorization procedures adopted by the states party to the Antarctic Treaty

Bouvet Island

the laws of Norway,
where applicable,
apply

French Southern and Antarctic Lands

the laws of France,
where applicable,
apply

Heard Island and McDonald Islands

the laws of Australia,
where applicable,
apply

South Georgia and the South Sandwich Islands

the laws of the UK, where applicable, apply; the senior magistrate from the Falkland Islands presides over the Magistrates Court

Arctic Region

4 entries

Greenland

the laws of Denmark,
where applicable,
apply

Iceland

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

Jan Mayen

the laws of Norway,
where applicable,
apply

Svalbard

the laws of Norway,
where applicable,
apply

Asia

23 entries

Afghanistan

based on mixed civil and Sharia law; has not accepted compulsory ICJ jurisdiction

Armenia

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

Azerbaijan

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

Bangladesh

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

Bhutan

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

British Indian Ocean Territory

the laws of the UK,
where applicable,
apply

China

based on civil law system;
derived from Soviet and continental civil code legal principles;
legislature retains power to interpret statutes;
constitution ambiguous on judicial review of legislation;
has not accepted compulsory ICJ jurisdiction

Georgia

based on civil law system; accepts compulsory ICJ jurisdiction

India

based on English common law;
judicial review of legislative acts;
accepts compulsory ICJ jurisdiction with reservations;
separate personal law codes apply to Muslims, Christians, and Hindus

Japan

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

Kazakhstan

based on Islamic law and Roman law; has not accepted compulsory ICJ jurisdiction

Korea, North now North Korea

based on Prussian civil law system with Japanese influences and Communist legal theory;
no judicial review of legislative acts;
has not accepted compulsory ICJ jurisdiction

Korea, South now South Korea

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

Kyrgyzstan

based on French and Russian laws; 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

Mongolia

blend of Soviet, German, and US systems that combine "continental" or "civil" code and case-precedent;
constitution ambiguous on judicial review of legislative acts;
has not accepted compulsory ICJ jurisdiction

Nepal

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

Pakistan

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

Russia

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

Sri Lanka

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

Tajikistan

based on civil law system;
no judicial review of legislative acts;
has not accepted compulsory ICJ jurisdiction

Turkmenistan

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

Uzbekistan

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

Central America and the Caribbean

32 entries

Anguilla

based on English common law

Antigua and Barbuda

based on English common law

Aruba

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

Bahamas, The now The Bahamas

based on English common law

Barbados

English common law;
no judicial review of legislative acts;
accepts compulsory ICJ jurisdiction, with reservations

Belize

English law; has not accepted compulsory ICJ jurisdiction

British Virgin Islands

English law

Cayman Islands

British common law and local statutes

Costa Rica

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

Cuba

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

Dominica

based on English common law; accepts ICJ jurisdiction

Dominican Republic

based on French civil codes;
Criminal Procedures Code modified in 2004 to include important elements of an accusatory system;
accepts compulsory ICJ jurisdiction

El Salvador

based on civil and Roman law with traces of common law;
judicial review of legislative acts in the Supreme Court;
has not accepted compulsory ICJ jurisdiction

Grenada

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

Guatemala

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

Haiti

based on Roman civil law system; accepts compulsory ICJ jurisdiction

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

Jamaica

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

Montserrat

English common law and statutory law

Navassa Island

the laws of the US,
where applicable,
apply

Netherlands Antilles

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

Nicaragua

civil law system;
Supreme Court may review administrative acts;
accepts compulsory ICJ jurisdiction

Panama

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

Puerto Rico

based on Spanish civil code and within the US Federal system of justice

Saint Barthelemy

the laws of France,
where applicable,
apply

Saint Kitts and Nevis

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

Saint Lucia

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

Saint Martin

the laws of France,
where applicable,
apply

Saint Vincent and the Grenadines

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

Trinidad and Tobago

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

Turks and Caicos Islands

based on laws of England and Wales, with a few adopted from Jamaica and The Bahamas

Virgin Islands

based on US laws

Europe

49 entries

Albania

has a civil law system;
has not accepted compulsory ICJ jurisdiction;
has accepted jurisdiction of the International Criminal Court for its citizens

Andorra

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

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

Belarus

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

Belgium

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

Bosnia and Herzegovina

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

Bulgaria

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

Croatia

based on Austro-Hungarian law system with Communist law influences; has not accepted compulsory ICJ jurisdiction

Czech Republic now Czechia

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

Estonia

based on civil law system; accepts compulsory ICJ jurisdiction with reservations

European Union

comparable to the legal systems of member states; first supranational law system

Faroe Islands

the laws of Denmark,
where applicable,
apply

Finland

civil law system based on Swedish law;
the president may request the Supreme Court to review laws;
accepts compulsory ICJ jurisdiction with reservations

France

civil law system with indigenous concepts;
review of administrative but not legislative acts;
has not accepted compulsory ICJ jurisdiction

Germany

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

Gibraltar

the laws of the UK,
where applicable,
apply

Greece

based on codified Roman law;
judiciary divided into civil, criminal, and administrative courts;
accepts compulsory ICJ jurisdiction with reservations

Guernsey

the laws of the UK,
where applicable,
apply;
justice is administered by the Royal Court

Holy See (Vatican City)

based on Code of Canon Law and revisions to it

Hungary

based on the German-Austrian legal system; accepts compulsory ICJ jurisdiction with reservations

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

the laws of the UK,
where applicable,
apply and Manx statutes

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

Jersey

the laws of the UK,
where applicable,
apply and local statutes;
justice is administered by the Royal Court

Kosovo

evolving legal system based on terms of UN Special Envoy Martti AHTISAARI's Plan for Kosovo's supervised independence

Latvia

based on civil law system with traces of Socialist legal traditions and practices; has not accepted compulsory ICJ jurisdiction

Liechtenstein

local civil and penal codes based on civil law system; accepts compulsory ICJ jurisdiction with reservations

Lithuania

based on civil law system;
legislative acts can be appealed to the constitutional court;
has not accepted compulsory ICJ jurisdiction

Luxembourg

based on civil law system; accepts compulsory ICJ jurisdiction

Malta

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

Moldova

based on civil law system;
Constitutional Court reviews legality of legislative acts and governmental decisions of resolution;
accepts many UN and Organization for Security and Cooperation in Europe (OSCE) documents;
has not accepted compulsory ICJ jurisdiction

Monaco

based on French law; has not accepted compulsory ICJ jurisdiction

Montenegro

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

Netherlands

based on 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

Macedonia now North Macedonia

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

Norway

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

Poland

based on a 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, but rulings of the Constitutional Tribunal are final;
court decisions can be appealed to the European Court of Justice in Strasbourg;
accepts compulsory ICJ jurisdiction with reservations

Portugal

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

Romania

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

San Marino

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

Serbia

based on civil law system

Slovakia

civil law system based on Austro-Hungarian codes;
accepts compulsory ICJ jurisdiction with reservations;
legal code modified to comply with the obligations of Organization on Security and Cooperation in Europe (OSCE) and to expunge Marxist-Leninist legal theory

Slovenia

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

Spain

civil law system, with regional applications; accepts compulsory ICJ jurisdiction with reservations

Sweden

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

Switzerland

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

Ukraine

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

United Kingdom

based on common law tradition with early Roman and modern continental influences;
has nonbinding judicial review of Acts of Parliament under the Human Rights Act of 1998;
accepts compulsory ICJ jurisdiction, with reservations

Middle East

17 entries

Akrotiri

the Sovereign Base Area Administration has its own court system to deal with civil and criminal matters;
laws applicable to the Cypriot population are, as far as possible, the same as the laws of the Republic of Cyprus

Bahrain

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

Cyprus

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

Dhekelia

the Sovereign Base Area Administration has its own court system to deal with civil and criminal matters;
laws applicable to the Cypriot population are, as far as possible, the same as the laws of the Republic of Cyprus

Iran

based on Sharia law system; has not accepted compulsory ICJ jurisdiction

Iraq

based on European civil and Islamic law under the framework outlined in the Iraqi Constitution; has not accepted compulsory ICJ jurisdiction

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

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

Kuwait

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

Lebanon

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

Oman

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

Qatar

based on Islamic and civil law codes;
discretionary system of law controlled by the Amir, although civil codes are being implemented;
Islamic law dominates family and personal matters;
has not accepted compulsory ICJ jurisdiction

Saudi Arabia

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

Syria

based on a combination of French and Ottoman civil law;
Islamic law is used in the family court system;
has not accepted compulsory ICJ jurisdiction

Turkey now Turkiye

civil law system derived from various European continental legal systems;
note - member of the European Court of Human Rights (ECHR), although Turkey claims limited derogations on the ratified European Convention on Human Rights;
has not accepted compulsory ICJ jurisdiction

United Arab Emirates

based on a dual system of Sharia and civil courts; has not accepted compulsory ICJ jurisdiction

Yemen

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

North America

6 entries

Bermuda

English law

Canada

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

Clipperton Island

the laws of France,
where applicable,
apply

Mexico

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

Saint Pierre and Miquelon

the laws of France,
where applicable,
apply

United States

federal court system based on English common law;
each state has its own unique legal system, of which all but one (Louisiana, which is still influenced by the Napoleonic Code) is based on English common law;
judicial review of legislative acts;
has not accepted compulsory ICJ jurisdiction

Oceania

28 entries

American Samoa

Australia

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

Cook Islands

based on New Zealand law and English common law

Coral Sea Islands

the laws of Australia,
where applicable,
apply

Fiji

based on British system; has not accepted compulsory ICJ jurisdiction

French Polynesia

the laws of France,
where applicable,
apply

Guam

modeled on US; US federal laws apply

Kiribati

Marshall Islands

based on adapted Trust Territory laws, acts of the legislature, municipal, common, and customary laws; has not accepted compulsory ICJ jurisdiction

Micronesia, Federated States of now Federated States of Micronesia

based on adapted Trust Territory laws, acts of the legislature, municipal, common, and customary laws; has not accepted compulsory ICJ jurisdiction

Nauru

acts of the Nauru Parliament and British common law; accepts compulsory ICJ jurisdiction with reservations

New Caledonia

based on French civil law; the 1988 Matignon Accords grant substantial autonomy to the islands

New Zealand

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

Niue

English common law; note - Niue is self-governing, with the power to make its own laws

Norfolk Island

based on the laws of Australia, local ordinances and acts; English common law applies in matters not covered by either Australian or Norfolk Island law

Northern Mariana Islands

based on US system, except for customs, wages, immigration laws, and taxation

Palau

based on Trust Territory laws, acts of the legislature, municipal, common, and customary laws; has not accepted compulsory ICJ jurisdiction

Papua New Guinea

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

Pitcairn Islands

local island by-laws

Samoa

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

Solomon Islands

English common law, which is widely disregarded; has not accepted compulsory ICJ jurisdiction

Tokelau

New Zealand and local statutes

Tonga

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

Tuvalu

United States Pacific Island Wildlife Refuges

the laws of the US,
where applicable,
apply

Vanuatu

unified system being created from former dual French and British systems; has not accepted compulsory ICJ jurisdiction

Wake Island

the laws of the US,
where applicable,
apply

Wallis and Futuna

the laws of France,
where applicable,
apply

South America

13 entries

Argentina

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

Bolivia

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

Brazil

based on Roman codes; 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 - in June 2005, Chile completed overhaul of its criminal justice system to a new, US-style adversarial system

Colombia

based on Spanish law;
a new criminal code modeled after US procedures was enacted into law in 2004 and reached full implemention in January 2008;
judicial review of executive and legislative acts;
has not accepted compulsory ICJ jurisdiction

Ecuador

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

Falkland Islands (Islas Malvinas)

English common law

Guyana

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

Paraguay

based on Argentine codes, Roman law, and French codes;
judicial review of legislative acts in Supreme Court of Justice;
accepts compulsory ICJ jurisdiction

Peru

based on civil law system; accepts compulsory ICJ jurisdiction with reservations

Suriname

based on Dutch legal system incorporating French penal theory; accepts compulsory ICJ jurisdiction with reservations

Uruguay

based on Spanish civil law system; accepts compulsory ICJ jurisdiction

Venezuela

open, adversarial court system; has not accepted compulsory ICJ jurisdiction

Southeast Asia

17 entries

Ashmore and Cartier Islands

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

Brunei

based on English common law;
for Muslims, Islamic Sharia law supersedes civil law in a number of areas;
has not accepted compulsory ICJ jurisdiction

Burma now Burma (Myanmar)

based on English common 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;
accepts compulsory ICJ jurisdiction with reservations

Christmas Island

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

Cocos (Keeling) Islands

based upon the laws of Australia and local laws

Hong Kong

based on English common law

Indonesia

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

Laos

based on traditional customs, French legal norms and procedures, and socialist practice; has not accepted compulsory ICJ jurisdiction

Macau

based on Portuguese civil law system

Malaysia

based on English common law;
judicial review of legislative acts in the Supreme Court at request of supreme head of the federation;
Islamic law is applied to Muslims in matters of family law and religion;
has not accepted compulsory ICJ jurisdiction

Philippines

based on Spanish and Anglo-American law; accepts compulsory ICJ jurisdiction with reservations

Singapore

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

Taiwan

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

Thailand

based on civil law system, with influences of common law; has not accepted compulsory ICJ jurisdiction

Timor-Leste

UN-drafted legal system based on Indonesian law remains in place but is to be replaced by civil and penal codes based on Portuguese law;
these have passed but have not been promulgated;
has not accepted compulsory ICJ jurisdiction

Vietnam

based on communist legal theory and French civil law system; has not accepted compulsory ICJ jurisdiction

Central Intelligence Agency. The World Factbook 2008, “Legal system”, all entries. Archived by The Factbook, thefactbook.org/fields/legal-system/2008.

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