The CIA World Factbook Edition 2015 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 2015 edition carries it in 255 entries, in its Government section. Every entry is shown as that edition published it.

entries in the 2015 edition
255
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.

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World

1 entry

World

  • the legal systems of nearly all countries are generally modeled upon elements of five main types: civil law (including French law, the Napoleonic Code, Roman law, Roman-Dutch law, and Spanish law);
  • common law (including English and US law);
  • customary law;
  • mixed or pluralistic law;
  • and religious law (including Islamic law);
  • an additional type of legal system - international law - governs the conduct of independent nations in their relationships with one another

Africa

54 entries

Algeria

  • mixed legal system of French civil law and Islamic law;
  • judicial review of legislative acts in ad hoc Constitutional Council composed of various public officials including several Supreme Court justices

Angola

civil legal system based on Portuguese civil law; no judicial review of legislation

Benin

civil law system modeled largely on the French system and some customary law

Botswana

mixed legal system of civil law influenced by the Roman-Dutch model and also customary and common law

Burkina Faso

civil law based on the French model and customary law

Burundi

mixed legal system of Belgian civil law and customary law

Cabo Verde

civil law system of Portugal

Cameroon

mixed legal system of English common law, French civil law, and customary law

Central African Republic

civil law system based on the French model

Chad

mixed legal system of civil and customary law

Comoros

mixed legal system of Islamic religious law, the French civil code of 1975, and customary law

Congo, Democratic Republic Of The now Democratic Republic of the Congo

civil law system primarily based on Belgian law, but also customary, and tribal law

Congo, Republic Of The now Republic of the Congo

mixed legal system of French civil law and customary law

Cote D'Ivoire now Cote d'Ivoire

civil law system based on the French civil code; judicial review of legislation held in the Constitutional Chamber of the Supreme Court

Djibouti

mixed legal system based primarily on the French civil code (as it existed in 1997), Islamic religious law (in matters of family law and successions), and customary law

Egypt

  • mixed legal system based on Napoleonic civil and penal law, Islamic religious law, and vestiges of colonial-era laws;
  • judicial review of the constitutionality of laws by the Supreme Constitutional Court

Equatorial Guinea

mixed system of civil and customary law

Eritrea

mixed legal system of civil, customary, and Islamic religious law

Swaziland now Eswatini

mixed legal system of civil, common, and customary law

Ethiopia

civil law system

Gabon

mixed legal system of French civil law and customary law

Gambia, The now The Gambia

mixed legal system of English common law, Islamic law, and customary law

Ghana

mixed system of English common law and customary law

Guinea

civil law system based on the French model

Guinea-Bissau

mixed legal system of civil law which incorporated Portuguese law at independence and influenced by early French civil code and customary law

Kenya

mixed legal system of English common law, Islamic law, and customary law; judicial review in a new Supreme Court established pursuant to the new constitution

Lesotho

mixed legal system of English common law and Roman-Dutch law; judicial review of legislative acts in High Court and Court of Appeal

Liberia

mixed legal system of common law (based on Anglo-American law) and customary law

Libya

Libya's post-revolution legal system is in flux and driven by state and non-state entities

Madagascar

civil law system based on the old French civil code and customary law in matters of marriage, family, and obligation

Malawi

mixed legal system of English common law and customary law; judicial review of legislative acts in the Supreme Court of Appeal

Mali

civil law system based on the French civil law model and influenced by customary law; judicial review of legislative acts in Constitutional Court

Mauritania

mixed legal system of Islamic and French civil law

Mauritius

civil legal system based on French civil law with some elements of English common law

Morocco

mixed legal system of civil law based on French law and Islamic law; judicial review of legislative acts by Constitutional Court

Mozambique

  • mixed legal system of Portuguese civil law, and customary law;
  • note - in rural, predominately Muslim villages with no formal legal system, Islamic law may be applied

Namibia

mixed legal system of uncodified civil law based on Roman-Dutch law and customary law

Niger

mixed legal system of civil law (based on French civil law), Islamic law, and customary law

Nigeria

mixed legal system of English common law, Islamic law (in 12 northern states), and traditional law

Rwanda

mixed legal system of civil law, based on German and Belgian models, and customary law; judicial review of legislative acts in the Supreme Court

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

English common law and local statutes

Sao Tome And Principe now Sao Tome and Principe

mixed legal system of civil law base on the Portuguese model and customary law

Senegal

civil law system based on French law; judicial review of legislative acts in Constitutional Court

Seychelles

mixed legal system of English common law, French civil law, and customary law

Sierra Leone

mixed legal system of English common law and customary law

Somalia

mixed legal system of civil law, Islamic law, and customary law (referred to as Xeer)

South Africa

mixed legal system of Roman-Dutch civil law, English common law, and customary law

Sudan

mixed legal system of Islamic law and English common law

Tanzania

English common law; judicial review of legislative acts limited to matters of interpretation

Togo

customary law system

Tunisia

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

Uganda

mixed legal system of English common law and customary law

Zambia

mixed legal system of English common law and customary law

Zimbabwe

mixed legal system of English common law, Roman-Dutch civil law, and customary law

Antarctic Region

4 entries

Bouvet Island

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

French Southern And Antarctic Lands now French Southern and Antarctic Lands

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

Heard Island And Mcdonald Islands now Heard Island and McDonald Islands

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

South Georgia And South Sandwich Islands now South Georgia and the South Sandwich Islands

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

Arctic Region

4 entries

Greenland

the laws of Denmark apply

Iceland

civil law system influenced by the Danish model

Jan Mayen

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

Svalbard

  • the laws of Norway where applicable apply only the laws of Norway made explicitly applicable to Svalbard have effect there;
  • the Svalbard Act and the Svalbard Environmental Protection Act, and certain regulations, apply only to Svalbard;
  • the Spitsbergen Treaty and the Svalbard Treaty grants certain rights to citizens and corporations of signatory nations

Asia

23 entries

Afghanistan

mixed legal system of civil, customary, and Islamic law

Armenia

civil law system

Azerbaijan

civil law system

Bangladesh

mixed legal system of mostly English common law and Islamic law

Bhutan

civil law based on Buddhist religious law

British Indian Ocean Territory

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

China

  • civil law influenced by Soviet and continental European civil law systems;
  • legislature retains power to interpret statutes;
  • note - criminal procedure law revised in early 2012

Georgia

civil law system

India

  • common law system based on the English model;
  • separate personal law codes apply to Muslims, Christians, and Hindus;
  • judicial review of legislative acts

Japan

  • civil law system based on German model;
  • system also reflects Anglo-American influence and Japanese traditions;
  • judicial review of legislative acts in the Supreme Court

Kazakhstan

civil law system influenced by Roman-Germanic law and by the theory and practice of the Russian Federation

Korea, North now North Korea

civil law system based on the Prussian model; system influenced by Japanese traditions and Communist legal theory

Korea, South now South Korea

mixed legal system combining European civil law, Anglo-American law, and Chinese classical thought

Kyrgyzstan

civil law system which includes features of French civil law and Russian Federation laws

Maldives

Islamic religious legal system with English common law influences, primarily in commercial matters

Mongolia

civil law system influenced by Soviet and Romano-Germanic legal systems; constitution ambiguous on judicial review of legislative acts

Nepal

English common law and Hindu legal concepts

Pakistan

common law system with Islamic law influence

Russia

civil law system; judicial review of legislative acts

Sri Lanka

mixed legal system of Roman-Dutch civil law, English common law, and Jaffna Tamil customary law

Tajikistan

civil law system

Turkmenistan

civil law system with Islamic law influences

Uzbekistan

civil law system

Central America and the Caribbean

33 entries

Anguilla

common law based on the English model

Antigua And Barbuda now Antigua and Barbuda

common law based on the English model

Aruba

civil law system based on the Dutch civil code

Bahamas, The now The Bahamas

common law system based on the English model

Barbados

English common law; no judicial review of legislative acts

Belize

English common law

British Virgin Islands

English common law

Cayman Islands

English common law and local statutes

Costa Rica

civil law system based on Spanish civil code; judicial review of legislative acts in the Supreme Court

Cuba

civil law system based on Spanish civil code

Curacao

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

Dominica

common law based on the English model

Dominican Republic

civil law system based on the French civil code; Criminal Procedures Code modified in 2004 to include important elements of an accusatory system

El Salvador

civil law system with minor common law influence; judicial review of legislative acts in the Supreme Court

Grenada

common law based on English model

Guatemala

civil law system; judicial review of legislative acts

Haiti

civil law system strongly influenced by Napoleonic Code

Honduras

civil law system

Jamaica

common law system based on the English model

Montserrat

English common law

Navassa Island

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

Nicaragua

civil law system; Supreme Court may review administrative acts

Panama

civil law system; judicial review of legislative acts in the Supreme Court of Justice

Puerto Rico

civil law system based on the Spanish civil code and within the framework of the US federal system

Saint Barthelemy

French civil law

Saint Kitts And Nevis now Saint Kitts and Nevis

English common law

Saint Lucia

English common law

Saint Martin

French civil law

Saint Vincent And The Grenadines now Saint Vincent and the Grenadines

English common law

Sint Maarten

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

Trinidad And Tobago now Trinidad and Tobago

English common law; judicial review of legislative acts in the Supreme Court

Turks And Caicos Islands now Turks and Caicos Islands

mixed legal system of English common law and civil law

Virgin Islands

US common law

Europe

49 entries

Albania

civil law system except in the northern rural areas where customary law known as the "Code of Leke" prevails

Andorra

mixed legal system of civil and customary law with the influence of canon law

Austria

Published as “Legal system”

civil law system; judicial review of legislative acts by the Constitutional Court

Published as “Legal system”

civil law system; judicial review of legislative acts by the Constitutional Court

Belarus

civil law system; note - nearly all major codes (civil, civil procedure, criminal, criminal procedure, family, and labor) have been revised and came into force in 1999 or 2000

Belgium

  • civil law system based on the French Civil Code;
  • note - Belgian law continues to be modified in conformance with the legislative norms mandated by the European Union;
  • judicial review of legislative acts

Bosnia And Herzegovina now Bosnia and Herzegovina

civil law system; Constitutional Court review of legislative acts

Bulgaria

civil law

Croatia

  • civil law system influenced by legal heritage of Austria-Hungary;
  • note - Croatian law was fully harmonized with the European Community acquis as of the June 2010 completion of EU accession negotiations

Czech Republic now Czechia

new civil code enacted in 2014, replacing civil code of 1964 - based on former Austro-Hungarian civil codes and socialist theory - and reintroducing former Czech legal terminology

Denmark

civil law; judicial review of legislative acts

Estonia

civil law system

European Union

  • unique supranational law system in which, according to an interpretive declaration of member-state governments appended to the Treaty of Lisbon, "the Treaties and the law adopted by the Union on the basis of the Treaties have primacy over the law of Member States" under conditions laid down in the case law of the Court of Justice;
  • key principles of EU law include fundamental rights as guaranteed by the Charter of Fundamental Rights and as resulting from constitutional traditions common to the EU's states;
  • EU law is divided into 'primary' and 'secondary' legislation;
  • the treaties (primary legislation) are the basis for all EU action;
  • secondary legislation - which includes directives, regulations, and decisions - are derived from the principles and objectives set out in the treaties

Faroe Islands

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

Finland

civil law system based on the Swedish model

France

civil law; review of administrative but not legislative acts

Germany

civil law system

Gibraltar

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

Greece

civil legal system based on Roman law

Guernsey

customary legal system based on Norman customary law, and includes elements of the French Civil Code and English common law

Holy See (Vatican City)

religious legal system based on canon (religious) law

Hungary

civil legal system influenced by the German model

Ireland

common law system based on the English model but substantially modified by customary law; judicial review of legislative acts in Supreme Court

Isle Of Man now Isle of Man

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

Italy

civil law system; judicial review of legislation under certain conditions in Constitutional Court

Jersey

  • the laws of the UK,
  • where applicable,
  • apply;
  • local statutes

Kosovo

civil law system; note- the European Union Rule of Law Mission (EULEX) retains limited executive powers related to the investigation of such issues as war crimes

Latvia

civil law system with traces of socialist legal traditions and practices

Liechtenstein

civil law system influenced by Swiss, Austrian, and German law

Lithuania

civil law system; legislative acts can be appealed to the constitutional court

Luxembourg

civil law system

Malta

mixed legal system of English common law and civil law (based on the Roman and Napoleonic civil codes)

Moldova

civil law system with Germanic law influences; Constitutional Court review of legislative acts

Monaco

civil law system influenced by French legal tradition

Montenegro

civil law

Netherlands

civil law system based on the French system; constitution does not permit judicial review of acts of the States General

Macedonia now North Macedonia

civil law system; judicial review of legislative acts

Norway

mixed legal system of civil, common, and customary law; Supreme Court can advise on legislative acts

Poland

  • civil law system;
  • changes gradually being introduced as part of broader democratization process;
  • limited judicial review of legislative acts, but rulings of the Constitutional Tribunal are final

Portugal

civil law system; Constitutional Court review of legislative acts

Romania

civil law system

San Marino

civil law system with Italian civil law influences

Serbia

civil law system

Slovakia

  • civil law system based on Austro-Hungarian codes;
  • note - legal code modified to comply with the obligations of Organization on Security and Cooperation in Europe

Slovenia

civil law system

Spain

civil law system with regional variations

Sweden

civil law system influenced by Roman-Germanic law and customary law

Switzerland

civil law system; judicial review of legislative acts, except for federal decrees of a general obligatory character

Ukraine

civil law system; judicial review of legislative acts

United Kingdom

common law system; has nonbinding judicial review of Acts of Parliament under the Human Rights Act of 1998

Middle East

17 entries

Akrotiri

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

Bahrain

mixed legal system of Islamic law, English common law, Egyptian civil, criminal, and commercial codes; customary law

Cyprus

mixed legal system of English common law and civil law with European law supremacy

Dhekelia

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

Iran

religious legal system based on secular and Islamic law

Iraq

mixed legal system of civil and Islamic law

Israel

mixed legal system of English common law, British Mandate regulations, and Jewish, Christian, and Muslim religious laws

Jordan

mixed legal system of civil law and Islamic religious law; judicial review of legislative acts in a specially provided High Tribunal

Kuwait

mixed legal system consisting of English common law, French civil law, and Islamic religious law

Lebanon

mixed legal system of civil law based on the French civil code, Ottoman legal tradition, and religious laws covering personal status, marriage, divorce, and other family relations of the Jewish, Islamic, and Christian communities

Oman

mixed legal system of Anglo-Saxon law and Islamic law

Qatar

mixed legal system of civil law and Islamic law (in family and personal matters)

Saudi Arabia

  • Islamic (sharia) legal system with some elements of Egyptian, French, and customary law;
  • note - several secular codes have been introduced;
  • commercial disputes handled by special committees

Syria

mixed legal system of civil and Islamic law (for family courts)

Turkey now Turkiye

civil law system based on various European legal systems notably the Swiss civil code

United Arab Emirates

mixed legal system of Islamic law and civil law

Yemen

mixed legal system of Islamic law, Napoleonic law, English common law, and customary law

North America

6 entries

Bermuda

English common law

Canada

common law system except in Quebec, where civil law based on the French civil code prevails

Clipperton Island

the laws of France apply

Mexico

civil law system with US constitutional law influence; judicial review of legislative acts

Saint Pierre And Miquelon now Saint Pierre and Miquelon

French civil law

United States

  • common law system based on English common law at the federal level;
  • state legal systems based on common law except Louisiana, which is based on Napoleonic civil code;
  • judicial review of legislative acts

Oceania

34 entries

American Samoa

mixed legal system of US common law and customary law

Australia

common law system based on the English model

Cook Islands

common law similar to New Zealand common law

Coral Sea Islands

  • the common law legal system of Australia,
  • where applicable,
  • applies

Fiji

common law system based on the English model

French Polynesia

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

Guam

common law modeled on US system; US federal laws apply

Howland Island

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

Jarvis Island

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

Johnston Atoll

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

Kingman Reef

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

Kiribati

English common law supplemented by customary law

Marshall Islands

mixed legal system of US and English common law, customary law, and local statutes

Micronesia, Federated States Of now Federated States of Micronesia

mixed legal system of common and customary law

Midway Islands

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

Nauru

mixed legal system of common law based on the English model and customary law

New Caledonia

civil law system based on French law; the 1988 Matignon Accords (signed in the Matignon Hotel) set up a 10-year period of development during which the Kanak community received substantial autonomy but agreed not to raise the independence issue

New Zealand

  • common law system,
  • based on English model,
  • with special legislation and land courts for the Maori

Niue

English common law

Norfolk Island

English common law and the laws of Australia

Northern Mariana Islands

US system applies, except for customs, wages, immigration laws, and taxation

Palau

mixed legal system of civil, common, and customary law

Palmyra Atoll

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

Papua New Guinea

mixed legal system of English common law and customary law

Pitcairn Islands

local island by-laws

Samoa

mixed legal system of English common law and customary law; judicial review of legislative acts with respect to fundamental rights of the citizen

Solomon Islands

mixed legal system of English common law and customary law

Tokelau

common law system of New Zealand

Tonga

English common law

Tuvalu

mixed legal system of English common law and local customary law

United States Pacific Island Wildlife Refuges

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

Vanuatu

mixed legal system of English common law, French law, and customary law

Wake Island

US common law

Wallis And Futuna now Wallis and Futuna

French civil law

South America

13 entries

Argentina

  • civil law system based on West European legal systems;
  • note - in 2014, Congress passed government-backed reform to the civil code that will go into effect in 2016

Bolivia

civil law system with influences from Roman, Spanish, canon (religious), French, and indigenous law

Brazil

civil law; note - a new civil law code was enacted in 2002 replacing the 1916 code

Chile

civil law system influenced by several West European civil legal systems; judicial review of legislative acts by the Constitutional Tribunal

Colombia

civil law system influenced by the Spanish and French civil codes

Ecuador

civil law based on the Chilean civil code with modifications; traditional law in indigenous communities

Falkland Islands (Islas Malvinas)

English common law and local statutes

Guyana

  • common law system,
  • based on the English model,
  • with some Roman-Dutch civil law influence

Paraguay

civil law system with influences from Argentine, Spanish, Roman, and French civil law models; judicial review of legislative acts in Supreme Court of Justice

Peru

civil law system

Suriname

civil law system influenced by Dutch civil law; note - the Commissie Nieuw Surinaamse Burgerlijk Wetboek completed drafting a new civil code in February 2009

Uruguay

civil law system based on the Spanish civil code

Venezuela

civil law system based on the Spanish civil code

Southeast Asia

17 entries

Ashmore And Cartier Islands now Ashmore and Cartier Islands

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

Brunei

  • mixed legal system based on English common law and Islamic law;
  • note - in May 2014, the first phase of a sharia-based penal codes was instituted, which applies to Muslims and non-Muslims and exists in parallel to the existing common law-based code

Burma now Burma (Myanmar)

mixed legal system of English common law (as introduced in codifications designed for colonial India) and customary law

Cambodia

civil law system (influenced by the UN Transitional Authority in Cambodia) customary law, Communist legal theory, and common law

Christmas Island

legal system is under the authority of the governor general of Australia and Australian law

Cocos (Keeling) Islands

common law based on the Australian model

Hong Kong

mixed legal system of common law based on the English model and Chinese customary law (in matters of family and land tenure)

Indonesia

civil law system based on the Roman-Dutch model and influenced by customary law

Laos

civil law system similar in form to the French system

Macau

civil law system based on the Portuguese model

Malaysia

  • mixed legal system of English common law, Islamic law, and customary law;
  • judicial review of legislative acts in the Federal Court at request of supreme head of the federation

Philippines

mixed legal system of civil, common, Islamic, and customary law

Singapore

English common law

Taiwan

civil law system

Thailand

civil law system with common law influences

Timor-Leste

  • civil law system based on the Portuguese model;
  • note - penal and civil law codes to replace the Indonesian codes were passed by Parliament and promulgated in 2009 and 2011, respectively

Vietnam

civil law system; note - the civil code of 2005 reflects a European-style civil law

Cite this page

Central Intelligence Agency. The World Factbook 2015, “Legal system”, all entries. Archived by The Factbook, thefactbook.org/fields/legal-system/2015.

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