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Afghanistan Afghanistan a new legal system has not been adopted but all factions tacitly agree they will follow Shari'a (Islamic law) according to the new constitution, no law should be "contrary to Islam"; the state is obliged to create a prosperous and progressive society based on social justice, protection of human dignity, protection of human rights, realization of democracy, and to ensure national unity and equality among all ethnic groups and tribes; the state shall abide by the UN charter, international treaties, international conventions that Afghanistan signed, and the Universal Declaration of Human Rights
Akrotiri Akrotiri - the laws of the UK, where applicable, apply
Albania Albania has not accepted compulsory ICJ jurisdiction has a civil law system; has not accepted compulsory ICJ jurisdiction; has accepted jurisdiction of the International Criminal Court for its citizens
Algeria 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 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
American Samoa American Samoa NA NA
Andorra Andorra based on French and Spanish civil codes; no judicial review of legislative acts; 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
Angola Angola based on Portuguese civil law system and customary law; recently modified to accommodate political pluralism and increased use of free markets based on Portuguese civil law system and customary law; recently modified to accommodate political pluralism and increased use of free markets
Anguilla Anguilla based on English common law based on English common law
Antarctica Antarctica 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. 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 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, 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 latitude South, is subject to a number of relevant legal instruments and authorization procedures adopted by the states party to the Antarctic Treaty.
Antigua and Barbuda Antigua and Barbuda based on English common law based on English common law
Argentina Argentina mixture of US and West European legal systems; has not accepted compulsory ICJ jurisdiction mixture of US and West European legal systems; has not accepted compulsory ICJ jurisdiction
Armenia Armenia based on civil law system based on civil law system
Aruba Aruba based on Dutch civil law system, with some English common law influence based on Dutch civil law system, with some English common law influence
Ashmore and Cartier Islands Ashmore and Cartier Islands the laws of the Northern Territory of Australia, where applicable, apply the laws of the Commonwealth of Australia and the laws of the Northern Territory of Australia, where applicable, apply
Australia Australia based on English common law; accepts compulsory ICJ jurisdiction, with reservations based on English common law; accepts compulsory ICJ jurisdiction, with reservations
Austria Austria 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 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
Azerbaijan Azerbaijan based on civil law system based on civil law system
Bahamas, The Bahamas, The based on English common law based on English common law
Bahrain Bahrain based on Islamic law and English common law based on Islamic law and English common law
Baker Island Baker Island the laws of the US, where applicable, apply the laws of the US, where applicable, apply
Bangladesh Bangladesh based on English common law based on English common law
Barbados Barbados English common law; no judicial review of legislative acts English common law; no judicial review of legislative acts
Bassas da India Bassas da India the laws of France, where applicable, apply the laws of France, where applicable, apply
Belarus Belarus based on civil law system based on civil law system
Belgium Belgium civil law system influenced by English constitutional theory; judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations civil law system influenced by English constitutional theory; judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations
Belize Belize English law English law
Benin Benin based on French civil law and customary law; has not accepted compulsory ICJ jurisdiction based on French civil law and customary law; has not accepted compulsory ICJ jurisdiction
Bermuda Bermuda English law English law
Bhutan Bhutan based on Indian law and English common law; has not accepted compulsory ICJ jurisdiction based on Indian law and English common law; has not accepted compulsory ICJ jurisdiction
Bolivia Bolivia based on Spanish law and Napoleonic Code; has not accepted compulsory ICJ jurisdiction based on Spanish law and Napoleonic Code; has not accepted compulsory ICJ jurisdiction
Bosnia and Herzegovina Bosnia and Herzegovina based on civil law system based on civil law system
Botswana Botswana based on Roman-Dutch law and local customary law; judicial review limited to matters of interpretation; 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
Bouvet Island Bouvet Island the laws of Norway, where applicable, apply the laws of Norway, where applicable, apply
Brazil Brazil based on Roman codes; has not accepted compulsory ICJ jurisdiction based on Roman codes; has not accepted compulsory ICJ jurisdiction
British Indian Ocean Territory British Indian Ocean Territory the laws of the UK, where applicable, apply the laws of the UK, where applicable, apply
British Virgin Islands British Virgin Islands English law English law
Brunei Brunei based on English common law; for Muslims, Islamic Shari'a law supersedes civil law in a number of areas based on English common law; for Muslims, Islamic Shari'a law supersedes civil law in a number of areas
Bulgaria Bulgaria civil law and criminal law based on Roman law; accepts compulsory ICJ jurisdiction civil law and criminal law based on Roman law; accepts compulsory ICJ jurisdiction
Burkina Faso Burkina Faso based on French civil law system and customary law based on French civil law system and customary law
Burma Burma has not accepted compulsory ICJ jurisdiction has not accepted compulsory ICJ jurisdiction
Burundi Burundi based on German and Belgian civil codes and customary law; has not accepted compulsory ICJ jurisdiction based on German and Belgian civil codes and customary law; has not accepted compulsory ICJ jurisdiction
Cambodia 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 in recent years 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 in recent years
Cameroon Cameroon based on French civil law system, with common law influence; has not accepted compulsory ICJ jurisdiction based on French civil law system, with common law influence; has not accepted compulsory ICJ jurisdiction
Canada Canada based on English common law, except in Quebec, where civil law system based on French law prevails; accepts compulsory ICJ jurisdiction, with reservations based on English common law, except in Quebec, where civil law system based on French law prevails; accepts compulsory ICJ jurisdiction, with reservations
Cape Verde Cape Verde derived from the legal system of Portugal derived from the legal system of Portugal
Cayman Islands Cayman Islands British common law and local statutes British common law and local statutes
Central African Republic Central African Republic based on French law based on French law
Chad Chad based on French civil law system and Chadian customary law; has not accepted compulsory ICJ jurisdiction based on French civil law system and Chadian customary law; has not accepted compulsory ICJ jurisdiction
Chile 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 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: Chile is in the process of completely overhauling its criminal justice system; a new, US-style adversarial system is being gradually implemented throughout the country with the final stage of implementation in the Santiago metropolitan region expected in June 2005
China China 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 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
Christmas Island Christmas Island under the authority of the governor general of Australia and Australian law under the authority of the governor general of Australia and Australian law
Clipperton Island Clipperton Island the laws of France, where applicable, apply the laws of France, where applicable, apply
Cocos (Keeling) Islands Cocos (Keeling) Islands based upon the laws of Australia and local laws based upon the laws of Australia and local laws
Colombia Colombia based on Spanish law; a new criminal code modeled after US procedures was enacted in 1992-93; judicial review of executive and legislative acts; accepts compulsory ICJ jurisdiction, with reservations based on Spanish law; a new criminal code modeled after US procedures was enacted into law in 2004; judicial review of executive and legislative acts; accepts compulsory ICJ jurisdiction, with reservations
Comoros Comoros French and Muslim law in a new consolidated code French and Sharia (Islamic) law in a new consolidated code
Congo, Democratic Republic of the Congo, Democratic Republic of the based on Belgian civil law system and tribal law; has not accepted compulsory ICJ jurisdiction based on Belgian civil law system and tribal law; has not accepted compulsory ICJ jurisdiction
Congo, Republic of the Congo, Republic of the based on French civil law system and customary law based on French civil law system and customary law
Cook Islands Cook Islands based on New Zealand law and English common law based on New Zealand law and English common law
Coral Sea Islands Coral Sea Islands the laws of Australia, where applicable, apply the laws of Australia, where applicable, apply
Costa Rica Costa Rica based on Spanish civil law system; judicial review of legislative acts in the Supreme Court; has accepted compulsory ICJ jurisdiction based on Spanish civil law system; judicial review of legislative acts in the Supreme Court; has accepted compulsory ICJ jurisdiction
Cote d'Ivoire Cote d'Ivoire 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 and customary law; judicial review in the Constitutional Chamber of the Supreme Court; has not accepted compulsory ICJ jurisdiction
Croatia Croatia based on civil law system based on civil law system
Cuba Cuba based on Spanish and American law, with large elements of Communist legal theory; has not accepted compulsory ICJ jurisdiction based on Spanish and American law, with large elements of Communist legal theory; has not accepted compulsory ICJ jurisdiction
Cyprus Cyprus based on common law, with civil law modifications based on common law, with civil law modifications
Czech Republic Czech Republic 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 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 Denmark civil law system; judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations civil law system; judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations
Dhekelia Dhekelia - the laws of the UK, where applicable, apply
Djibouti Djibouti based on French civil law system, traditional practices, and Islamic law based on French civil law system, traditional practices, and Islamic law
Dominica Dominica based on English common law based on English common law
Dominican Republic Dominican Republic based on French civil codes based on French civil codes; undergoing modification in 2004 towards an accusatory system
East Timor East Timor - UN-drafted legal system based on Indonesian law remains in place but will be replaced by civil and penal codes based on Portuguese law (2004)
Ecuador Ecuador based on civil law system; has not accepted compulsory ICJ jurisdiction based on civil law system; has not accepted compulsory ICJ jurisdiction
Egypt Egypt 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 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
El Salvador El Salvador 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 civil and Roman law, with traces of common law; judicial review of legislative acts in the Supreme Court; accepts compulsory ICJ jurisdiction, with reservations
Equatorial Guinea Equatorial Guinea partly based on Spanish civil law and tribal custom partly based on Spanish civil law and tribal custom
Eritrea Eritrea 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 primary basis is the Ethiopian legal code of 1957, with revisions; new civil, commercial, and penal codes have not yet been promulgated; also relies on customary and post-independence-enacted laws and, for civil cases involving Muslims, Sharia law
Estonia Estonia based on civil law system; no judicial review of legislative acts based on civil law system; no judicial review of legislative acts
Ethiopia Ethiopia currently transitional mix of national and regional courts currently transitional mix of national and regional courts
Europa Island Europa Island the laws of France, where applicable, apply the laws of France, where applicable, apply
Falkland Islands (Islas Malvinas) Falkland Islands (Islas Malvinas) English common law English common law
Faroe Islands Faroe Islands Danish Danish
Fiji Fiji based on British system based on British system
Finland Finland 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 based on Swedish law; the president may request the Supreme Court to review laws; accepts compulsory ICJ jurisdiction, with reservations
France France civil law system with indigenous concepts; review of administrative but not legislative acts civil law system with indigenous concepts; review of administrative but not legislative acts
French Guiana French Guiana French legal system French legal system
French Polynesia French Polynesia based on French system based on French system
French Southern and Antarctic Lands French Southern and Antarctic Lands the laws of France, where applicable, apply the laws of France, where applicable, apply
Gabon 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 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 Gambia, The based on a composite of English common law, Koranic law, and customary law; accepts compulsory ICJ jurisdiction, with reservations based on a composite of English common law, Koranic law, and customary law; accepts compulsory ICJ jurisdiction, with reservations
Georgia Georgia based on civil law system based on civil law system
Germany Germany civil law system with indigenous concepts; judicial review of legislative acts in the Federal Constitutional Court; has not accepted compulsory ICJ jurisdiction civil law system with indigenous concepts; judicial review of legislative acts in the Federal Constitutional Court; has not accepted compulsory ICJ jurisdiction
Ghana Ghana based on English common law and customary law; has not accepted compulsory ICJ jurisdiction based on English common law and customary law; has not accepted compulsory ICJ jurisdiction
Gibraltar Gibraltar English law English law
Glorioso Islands Glorioso Islands the laws of France, where applicable, apply the laws of France, where applicable, apply
Greece Greece based on codified Roman law; judiciary divided into civil, criminal, and administrative courts based on codified Roman law; judiciary divided into civil, criminal, and administrative courts
Greenland Greenland Danish Danish
Grenada Grenada based on English common law based on English common law
Guadeloupe Guadeloupe French legal system French legal system
Guam Guam modeled on US; US federal laws apply modeled on US; US federal laws apply
Guatemala Guatemala civil law system; judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction civil law system; judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
Guernsey Guernsey English law and local statute; justice is administered by the Royal Court English law and local statutes; justice is administered by the Royal Court
Guinea Guinea based on French civil law system, customary law, and decree; legal codes currently being revised; has not accepted compulsory ICJ jurisdiction based on French civil law system, customary law, and decree; legal codes currently being revised; has not accepted compulsory ICJ jurisdiction
Guinea-Bissau Guinea-Bissau NA NA
Guyana Guyana based on English common law with certain admixtures of Roman-Dutch law; has not accepted compulsory ICJ jurisdiction based on English common law with certain admixtures of Roman-Dutch law; has not accepted compulsory ICJ jurisdiction
Haiti Haiti based on Roman civil law system; accepts compulsory ICJ jurisdiction based on Roman civil law system; accepts compulsory ICJ jurisdiction
Heard Island and McDonald Islands Heard Island and McDonald Islands the laws of Australia, where applicable, apply the laws of Australia, where applicable, apply
Holy See (Vatican City) Holy See (Vatican City) NA based on Code of Canon Law and revisions to it
Honduras 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 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
Hong Kong Hong Kong based on English common law based on English common law
Howland Island Howland Island the laws of the US, where applicable, apply the laws of the US, where applicable, apply
Hungary Hungary rule of law based on Western model rule of law based on Western model
Iceland Iceland civil law system based on Danish law; has not accepted compulsory ICJ jurisdiction civil law system based on Danish law; has not accepted compulsory ICJ jurisdiction
India India based on English common law; limited judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations based on English common law; limited judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations; separate personal law codes apply to Muslims, Christians, and Hindus
Indonesia Indonesia based on Roman-Dutch law, substantially modified by indigenous concepts and by new criminal procedures code; has not accepted compulsory ICJ jurisdiction based on Roman-Dutch law, substantially modified by indigenous concepts and by new criminal procedures and election codes; has not accepted compulsory ICJ jurisdiction
Iran Iran the Constitution codifies Islamic principles of government the Constitution codifies Islamic principles of government
Iraq Iraq based on Islamic law in special religious courts, civil law system elsewhere; has not accepted compulsory ICJ jurisdiction based on civil and Islamic law under the Iraqi Interim Government (IG) and Transitional Administrative Law (TAL)
Ireland 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 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 Isle of Man English common law and Manx statute English common law and Manx statute
Israel 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 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
Italy 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 based on civil law system; appeals treated as new trials; judicial review under certain conditions in Constitutional Court; has not accepted compulsory ICJ jurisdiction
Jamaica Jamaica based on English common law; has not accepted compulsory ICJ jurisdiction based on English common law; has not accepted compulsory ICJ jurisdiction
Jan Mayen Jan Mayen the laws of Norway, where applicable, apply the laws of Norway, where applicable, apply
Japan Japan 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 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
Jarvis Island Jarvis Island the laws of the US, where applicable, apply the laws of the US, where applicable, apply
Jersey Jersey English law and local statute English law and local statute; justice is administered by the Royal Court
Johnston Atoll Johnston Atoll the laws of the US, where applicable, apply the laws of the US, where applicable, apply
Jordan 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 based on Islamic law and French codes; judicial review of legislative acts in a specially provided High Tribunal; has not accepted compulsory ICJ jurisdiction
Juan de Nova Island Juan de Nova Island the laws of France, where applicable, apply the laws of France, where applicable, apply
Kazakhstan Kazakhstan based on civil law system based on civil law system
Kenya Kenya 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 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
Kingman Reef Kingman Reef the laws of the US, where applicable, apply the laws of the US, where applicable, apply
Kiribati Kiribati NA NA
Korea, North Korea, North 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 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
Korea, South Korea, South combines elements of continental European civil law systems, Anglo-American law, and Chinese classical thought combines elements of continental European civil law systems, Anglo-American law, and Chinese classical thought
Kuwait Kuwait civil law system with Islamic law significant in personal matters; has not accepted compulsory ICJ jurisdiction civil law system with Islamic law significant in personal matters; has not accepted compulsory ICJ jurisdiction
Kyrgyzstan Kyrgyzstan based on civil law system based on civil law system
Laos Laos based on traditional customs, French legal norms and procedures, and Socialist practice based on traditional customs, French legal norms and procedures, and socialist practice
Latvia Latvia based on civil law system based on civil law system
Lebanon Lebanon mixture of Ottoman law, canon law, Napoleonic code, and civil law; no judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction mixture of Ottoman law, canon law, Napoleonic code, and civil law; no judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
Lesotho Lesotho 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 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
Liberia 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 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
Libya Libya 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 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
Liechtenstein Liechtenstein local civil and penal codes; accepts compulsory ICJ jurisdiction, with reservations local civil and penal codes; accepts compulsory ICJ jurisdiction, with reservations
Lithuania Lithuania based on civil law system; no judicial review of legislative acts based on civil law system; legislative acts can be appealed to the constitutional court
Luxembourg Luxembourg based on civil law system; accepts compulsory ICJ jurisdiction based on civil law system; accepts compulsory ICJ jurisdiction
Macau Macau based on Portuguese civil law system based on Portuguese civil law system
Macedonia Macedonia - based on civil law system; judicial review of legislative acts
Macedonia, The Former Yugoslav Republic of Macedonia, The Former Yugoslav Republic of based on civil law system; judicial review of legislative acts -
Madagascar Madagascar based on French civil law system and traditional Malagasy law; has not accepted compulsory ICJ jurisdiction based on French civil law system and traditional Malagasy law; has not accepted compulsory ICJ jurisdiction
Malawi Malawi 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 English common law and customary law; judicial review of legislative acts in the Supreme Court of Appeal; has not accepted compulsory ICJ jurisdiction
Malaysia Malaysia based on English common law; judicial review of legislative acts in the Supreme Court at request of supreme head of the federation; has not accepted compulsory ICJ jurisdiction based on English common law; judicial review of legislative acts in the Supreme Court at request of supreme head of the federation; has not accepted compulsory ICJ jurisdiction
Maldives Maldives based on Islamic law with admixtures of English common law primarily in commercial matters; has not accepted compulsory ICJ jurisdiction based on Islamic law with admixtures of English common law primarily in commercial matters; has not accepted compulsory ICJ jurisdiction
Mali Mali 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 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
Malta Malta based on English common law and Roman civil law; accepts compulsory ICJ jurisdiction, with reservations based on English common law and Roman civil law; accepts compulsory ICJ jurisdiction, with reservations
Marshall Islands Marshall Islands based on adapted Trust Territory laws, acts of the legislature, municipal, common, and customary laws based on adapted Trust Territory laws, acts of the legislature, municipal, common, and customary laws
Martinique Martinique French legal system French legal system
Mauritania Mauritania a combination of Shari'a (Islamic law) and French civil law a combination of Shari'a (Islamic law) and French civil law
Mauritius Mauritius based on French civil law system with elements of English common law in certain areas based on French civil law system with elements of English common law in certain areas
Mayotte Mayotte French law French law
Mexico Mexico mixture of US constitutional theory and civil law system; judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations mixture of US constitutional theory and civil law system; judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations
Micronesia, Federated States of Micronesia, Federated States of based on adapted Trust Territory laws, acts of the legislature, municipal, common, and customary laws based on adapted Trust Territory laws, acts of the legislature, municipal, common, and customary laws
Midway Islands Midway Islands the laws of the US, where applicable, apply the laws of the US, where applicable, apply
Moldova Moldova 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 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
Monaco Monaco based on French law; has not accepted compulsory ICJ jurisdiction based on French law; has not accepted compulsory ICJ jurisdiction
Mongolia Mongolia 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 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
Montserrat Montserrat English common law and statutory law English common law and statutory law
Morocco Morocco based on Islamic law and French and Spanish civil law system; judicial review of legislative acts in Constitutional Chamber of Supreme Court based on Islamic law and French and Spanish civil law system; judicial review of legislative acts in Constitutional Chamber of Supreme Court
Mozambique Mozambique based on Portuguese civil law system and customary law based on Portuguese civil law system and customary law
Namibia Namibia based on Roman-Dutch law and 1990 constitution based on Roman-Dutch law and 1990 constitution
Nauru Nauru acts of the Nauru Parliament and British common law acts of the Nauru Parliament and British common law
Navassa Island Navassa Island the laws of the US, where applicable, apply the laws of the US, where applicable, apply
Nepal Nepal based on Hindu legal concepts and English common law; has not accepted compulsory ICJ jurisdiction based on Hindu legal concepts and English common law; has not accepted compulsory ICJ jurisdiction
Netherlands Netherlands 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 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
Netherlands Antilles Netherlands Antilles based on Dutch civil law system, with some English common law influence based on Dutch civil law system with some English common law influence
New Caledonia New Caledonia the 1988 Matignon Accords grant substantial autonomy to the islands; formerly under French law the 1988 Matignon Accords grant substantial autonomy to the islands; formerly under French law
New Zealand New Zealand based on English law, with special land legislation and land courts for Maoris; accepts compulsory ICJ jurisdiction, with reservations based on English law, with special land legislation and land courts for the Maori; accepts compulsory ICJ jurisdiction with reservations
Nicaragua Nicaragua civil law system; Supreme Court may review administrative acts civil law system; Supreme Court may review administrative acts
Niger Niger based on French civil law system and customary law; has not accepted compulsory ICJ jurisdiction based on French civil law system and customary law; has not accepted compulsory ICJ jurisdiction
Nigeria Nigeria based on English common law, Islamic Shariah law (only in some northern states), and traditional law based on English common law, Islamic Shariah law (in 12 northern states), and traditional law
Niue Niue English common law English common law


note: Niue is self-governing, with the power to make its own laws
Norfolk Island 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 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 Northern Mariana Islands based on US system, except for customs, wages, immigration laws, and taxation based on US system, except for customs, wages, immigration laws, and taxation
Norway 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 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
Oman Oman based on English common law and Islamic law; ultimate appeal to the monarch; has not accepted compulsory ICJ jurisdiction based on English common law and Islamic law; ultimate appeal to the monarch; has not accepted compulsory ICJ jurisdiction
Pakistan Pakistan based on English common law with provisions to accommodate Pakistan's status as an Islamic state; accepts compulsory ICJ jurisdiction, with reservations based on English common law with provisions to accommodate Pakistan's status as an Islamic state; accepts compulsory ICJ jurisdiction, with reservations
Palau Palau based on Trust Territory laws, acts of the legislature, municipal, common, and customary laws based on Trust Territory laws, acts of the legislature, municipal, common, and customary laws
Palmyra Atoll Palmyra Atoll the laws of the US, where applicable, apply the laws of the US, where applicable, apply
Panama Panama based on civil law system; judicial review of legislative acts in the Supreme Court of Justice; accepts compulsory ICJ jurisdiction, with reservations based on civil law system; judicial review of legislative acts in the Supreme Court of Justice; accepts compulsory ICJ jurisdiction, with reservations
Papua New Guinea Papua New Guinea based on English common law based on English common law
Paraguay Paraguay based on Argentine codes, Roman law, and French codes; judicial review of legislative acts in Supreme Court of Justice based on Argentine codes, Roman law, and French codes; judicial review of legislative acts in Supreme Court of Justice
Peru Peru based on civil law system; has not accepted compulsory ICJ jurisdiction based on civil law system; has not accepted compulsory ICJ jurisdiction
Philippines Philippines based on Spanish and Anglo-American law; accepts compulsory ICJ jurisdiction, with reservations based on Spanish and Anglo-American law; accepts compulsory ICJ jurisdiction, with reservations
Pitcairn Islands Pitcairn Islands local island by-laws local island by-laws
Poland Poland 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 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
Portugal Portugal civil law system; the Constitutional Tribunal reviews the constitutionality of legislation; accepts compulsory ICJ jurisdiction, with reservations civil law system; the Constitutional Tribunal reviews the constitutionality of legislation; accepts compulsory ICJ jurisdiction, with reservations
Puerto Rico Puerto Rico based on Spanish civil code based on Spanish civil code and within the US Federal system of justice
Qatar Qatar discretionary system of law controlled by the amir, although civil codes are being implemented; Islamic law is significant in personal matters discretionary system of law controlled by the amir, although civil codes are being implemented; Islamic law dominates family and personal matters
Reunion Reunion French law French law
Romania Romania former mixture of civil law system and communist legal theory; is now based on the constitution of France's Fifth Republic former mixture of civil law system and communist legal theory; is now based on the constitution of France's Fifth Republic
Russia Russia based on civil law system; judicial review of legislative acts based on civil law system; judicial review of legislative acts
Rwanda 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 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 Saint Helena NA NA
Saint Kitts and Nevis Saint Kitts and Nevis based on English common law based on English common law
Saint Lucia Saint Lucia based on English common law based on English common law
Saint Pierre and Miquelon Saint Pierre and Miquelon French law with special adaptations for local conditions, such as housing and taxation French law with special adaptations for local conditions, such as housing and taxation
Saint Vincent and the Grenadines Saint Vincent and the Grenadines based on English common law based on English common law
Samoa 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 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
San Marino San Marino based on civil law system with Italian law influences; has not accepted compulsory ICJ jurisdiction based on civil law system with Italian law influences; has not accepted compulsory ICJ jurisdiction
Sao Tome and Principe Sao Tome and Principe based on Portuguese legal system and customary law; has not accepted compulsory ICJ jurisdiction based on Portuguese legal system and customary law; has not accepted compulsory ICJ jurisdiction
Saudi Arabia Saudi Arabia based on Islamic law, several secular codes have been introduced; commercial disputes handled by special committees; has not accepted compulsory ICJ jurisdiction based on Islamic law, several secular codes have been introduced; commercial disputes handled by special committees; has not accepted compulsory ICJ jurisdiction
Senegal 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; 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
Serbia and Montenegro Serbia and Montenegro - based on civil law system
Seychelles Seychelles based on English common law, French civil law, and customary law based on English common law, French civil law, and customary law
Sierra Leone Sierra Leone based on English law and customary laws indigenous to local tribes; has not accepted compulsory ICJ jurisdiction based on English law and customary laws indigenous to local tribes; has not accepted compulsory ICJ jurisdiction
Singapore Singapore based on English common law; has not accepted compulsory ICJ jurisdiction based on English common law; has not accepted compulsory ICJ jurisdiction
Slovakia Slovakia 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 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
Slovenia Slovenia based on civil law system based on civil law system
Solomon Islands Solomon Islands English common law English common law, which is widely disregarded
Somalia Somalia NA no national system; Shari'a and secular courts are in some localities
South Africa South Africa based on Roman-Dutch law and English common law; accepts compulsory ICJ jurisdiction, with reservations based on Roman-Dutch law and English common law; accepts compulsory ICJ jurisdiction, with reservations
South Georgia and the South Sandwich Islands South Georgia and the South Sandwich Islands the laws of the UK, where applicable, apply the laws of the UK, where applicable, apply; the senior magistrate from the Falkland Islands presides over the Magistrates Court
Spain Spain civil law system, with regional applications; has not accepted compulsory ICJ jurisdiction civil law system, with regional applications; has not accepted compulsory ICJ jurisdiction
Sri Lanka Sri Lanka a highly complex mixture of English common law, Roman-Dutch, Muslim, Sinhalese, and customary law; has not accepted compulsory ICJ jurisdiction a highly complex mixture of English common law, Roman-Dutch, Muslim, Sinhalese, and customary law; has not accepted compulsory ICJ jurisdiction
Sudan 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; some separate religious courts; 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
Suriname Suriname based on Dutch legal system incorporating French penal theory based on Dutch legal system incorporating French penal theory
Svalbard Svalbard NA NA
Swaziland Swaziland 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 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
Sweden Sweden civil law system influenced by customary law; accepts compulsory ICJ jurisdiction, with reservations civil law system influenced by customary law; accepts compulsory ICJ jurisdiction, with reservations
Switzerland 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 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
Syria Syria based on Islamic law and civil law system; special religious courts; has not accepted compulsory ICJ jurisdiction based on Islamic law and civil law system; special religious courts; has not accepted compulsory ICJ jurisdiction
Taiwan Taiwan based on civil law system; accepts compulsory ICJ jurisdiction, with reservations based on civil law system; accepts compulsory ICJ jurisdiction, with reservations
Tajikistan Tajikistan based on civil law system; no judicial review of legislative acts based on civil law system; no judicial review of legislative acts
Tanzania Tanzania based on English common law; judicial review of legislative acts limited to matters of interpretation; has not accepted compulsory ICJ jurisdiction based on English common law; judicial review of legislative acts limited to matters of interpretation; has not accepted compulsory ICJ jurisdiction
Thailand Thailand based on civil law system, with influences of common law; has not accepted compulsory ICJ jurisdiction based on civil law system, with influences of common law; has not accepted compulsory ICJ jurisdiction
Togo Togo French-based court system French-based court system
Tokelau Tokelau British and local statutes New Zealand and local statutes
Tonga Tonga based on English law based on English law
Trinidad and Tobago Trinidad and Tobago based on English common law; judicial review of legislative acts in the Supreme Court; has not accepted compulsory ICJ jurisdiction based on English common law; judicial review of legislative acts in the Supreme Court; has not accepted compulsory ICJ jurisdiction
Tromelin Island Tromelin Island the laws of France, where applicable, apply the laws of France, where applicable, apply
Tunisia Tunisia based on French civil law system and Islamic law; some judicial review of legislative acts in the Supreme Court in joint session based on French civil law system and Islamic law; some judicial review of legislative acts in the Supreme Court in joint session
Turkey Turkey derived from various European continental legal systems; accepts compulsory ICJ jurisdiction, with reservations civil law system derived from various European continental legal systems; accepts compulsory ICJ jurisdiction, with reservations; note - member of the European Court of Human Rights (ECHR), although Turkey claims limited derogations on the ratified European Convention on Human Rights
Turkmenistan Turkmenistan based on civil law system based on civil law system
Turks and Caicos Islands Turks and Caicos Islands based on laws of England and Wales, with a small number adopted from Jamaica and The Bahamas based on laws of England and Wales, with a few adopted from Jamaica and The Bahamas
Tuvalu Tuvalu NA NA
Uganda 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 in 1995, the government restored the legal system to one based on English common law and customary law; accepts compulsory ICJ jurisdiction, with reservations
Ukraine Ukraine based on civil law system; judicial review of legislative acts based on civil law system; judicial review of legislative acts
United Arab Emirates United Arab Emirates federal court system introduced in 1971; all emirates except Dubayy (Dubai) and Ra's al Khaymah have joined the federal system; all emirates have secular and Islamic law for civil, criminal, and high courts federal court system introduced in 1971; applies to all emirates except Dubayy (Dubai) and Ra's al Khaymah, which are not fully integrated into the federal system; all emirates have secular courts to adjudicate criminal, civil, and commercial matters and Islamic courts to review family and religious disputes
United Kingdom United Kingdom 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 common law tradition with early Roman and modern continental influences; has judicial review of Acts of Parliament under the Human Rights Act of 1998; accepts compulsory ICJ jurisdiction, with reservations
United States United States based on English common law; judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations federal court system based on English common law; each state has its own unique legal system, of which all but one (Louisiana's) is based on English common law; judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations
Uruguay Uruguay based on Spanish civil law system; accepts compulsory ICJ jurisdiction based on Spanish civil law system; accepts compulsory ICJ jurisdiction
Uzbekistan Uzbekistan evolution of Soviet civil law; still lacks independent judicial system evolution of Soviet civil law; still lacks independent judicial system
Vanuatu Vanuatu unified system being created from former dual French and British systems unified system being created from former dual French and British systems
Venezuela Venezuela based on organic laws as of July 1999; open, adversarial court system; has not accepted compulsory ICJ jurisdiction open, adversarial court system
Vietnam Vietnam based on communist legal theory and French civil law system based on communist legal theory and French civil law system
Virgin Islands Virgin Islands based on US laws based on US laws
Wake Island Wake Island the laws of the US, where applicable, apply the laws of the US, where applicable, apply
Wallis and Futuna Wallis and Futuna French legal system French legal system
World World all members of the UN plus Switzerland are parties to the statute that established the International Court of Justice (ICJ) or World Court all members of the UN are parties to the statute that established the International Court of Justice (ICJ) or World Court
Yemen Yemen based on Islamic law, Turkish law, English common law, and local tribal customary law; has not accepted compulsory ICJ jurisdiction based on Islamic law, Turkish law, English common law, and local tribal customary law; has not accepted compulsory ICJ jurisdiction
Yugoslavia Yugoslavia based on civil law system -
Zambia 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 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 Zimbabwe mixture of Roman-Dutch and English common law mixture of Roman-Dutch and English common law
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