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  Legal system (2002)Legal system (2007)
Afghanistan Afghanistan the Bonn Agreement calls for a judicial commission to rebuild the justice system in accordance with Islamic principles, international standards, the rule of law, and Afghan legal traditions based on mixed civil and Shari'a law; has not accepted compulsory ICJ jurisdiction
Akrotiri 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
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
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, 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. 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
Armenia Armenia based on civil law system based on civil law system; has not accepted compulsory ICJ jurisdiction
Azerbaijan Azerbaijan based on civil law system based on civil law system; has not accepted compulsory ICJ jurisdiction
Bahrain Bahrain based on Islamic law and English common law based on Islamic law and English common law; has not accepted compulsory ICJ jurisdiction
Bangladesh Bangladesh based on English common law based on English common law; has not accepted compulsory ICJ jurisdiction
Barbados Barbados English common law; no judicial review of legislative acts English common law; no judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations
Bassas da India Bassas da India the laws of France, where applicable, apply -
Belarus Belarus based on civil law system based on civil law system; has not accepted compulsory ICJ jurisdiction
Belgium Belgium civil law system influenced by English constitutional theory; judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations based on civil law system influenced by English constitutional theory; judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations
Bosnia and Herzegovina Bosnia and Herzegovina based on civil law system based on civil law system; has not accepted compulsory ICJ jurisdiction
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; accepts compulsory ICJ jurisdiction, with reservations
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; has not accepted compulsory ICJ jurisdiction
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 with reservations
Burkina Faso Burkina Faso based on French civil law system and customary law based on French civil law system and customary law; has not accepted compulsory ICJ jurisdiction
Burma Burma has not accepted compulsory ICJ jurisdiction based on English common 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; accepts compulsory ICJ jurisdiction with reservations
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; accepts compulsory ICJ jurisdiction
Cape Verde Cape Verde derived from the legal system of Portugal based on the legal system of Portugal; 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


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
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
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 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
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 and is gradually being implemented; judicial review of executive and legislative acts
Comoros Comoros French and Muslim law in a new consolidated code French and 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 a new constitution was adopted by referendum 18 December 2005; accepts compulsory ICJ jurisdiction, with reservations
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; accepts compulsory ICJ jurisdiction, with reservations
Croatia Croatia based on civil law system based on Austro-Hungarian law system with Communist law influences; has not accepted compulsory ICJ jurisdiction
Cuba Cuba based on Spanish and American law, with large elements of Communist legal theory; has not accepted compulsory ICJ jurisdiction based on Spanish civil law and influenced by American legal concepts, 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 English common law, with civil law modifications; accepts compulsory ICJ jurisdiction, with reservations
Dhekelia 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
Djibouti Djibouti based on French civil law system, traditional practices, and Islamic law based on French civil law system, traditional practices, and Islamic law; accepts ICJ jurisdiction, with reservations
Dominican Republic Dominican Republic based on French civil codes based on French civil codes; Criminal Procedures Code modified in 2004 to include important elements of an accusatory system; accepts compulsory ICJ jurisdiction
East Timor East Timor NA -
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 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
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
Eritrea Eritrea 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 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
Estonia Estonia based on civil law system; no judicial review of legislative acts based on civil law system; accepts compulsory ICJ jurisdiction with reservations
Ethiopia Ethiopia currently transitional mix of national and regional courts based on civil law; currently transitional mix of national and regional courts; has not accepted compulsory ICJ jurisdiction
Europa Island Europa Island the laws of France, where applicable, apply -
European Union European Union - comparable to the legal systems of member states; first supranational law system
Faroe Islands Faroe Islands Danish the laws of Denmark, where applicable, apply
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; has not accepted compulsory ICJ jurisdiction
French Guiana French Guiana French legal system -
French Polynesia French Polynesia based on French system the laws of France, where applicable, apply
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, Islamic law, and customary law; accepts compulsory ICJ jurisdiction with reservations
Georgia Georgia based on civil law system based on civil law system; accepts compulsory ICJ jurisdiction
Gibraltar Gibraltar English law the laws of the UK, where applicable, apply
Glorioso Islands Glorioso Islands 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; accepts compulsory ICJ jurisdiction with reservations
Greenland Greenland Danish the laws of Denmark, where applicable, apply
Guadeloupe Guadeloupe French legal system -
Guernsey Guernsey English law and local statute; justice is administered by the Royal Court the laws of the UK, where applicable, apply; 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; accepts compulsory ICJ jurisdiction with reservations
Guinea-Bissau Guinea-Bissau NA based on French civil law; accepts compulsory ICJ jurisdiction
Holy See (Vatican City) Holy See (Vatican City) based on canon law and revisions to it 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
Hungary Hungary rule of law based on Western model based German-Austrian legal system; accepts compulsory ICJ jurisdiction with reservations
India India based on English common law; limited judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations 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
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 based on Shari'a law system; has not accepted compulsory ICJ jurisdiction
Iraq Iraq based on Islamic law in special religious courts, civil law system elsewhere; has not accepted compulsory ICJ jurisdiction based on European civil and Islamic law under the framework outlined in the Iraqi Constitution; has not accepted compulsory ICJ jurisdiction
Isle of Man Isle of Man English common law and Manx statute the laws of the UK, where applicable, apply and Manx statutes
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 German civil law system with English-American influence; judicial review of legislative acts in the Supreme Court; accepts compulsory ICJ jurisdiction with reservations
Jersey Jersey English law and local statute the laws of the UK, where applicable, apply and local statutes; justice is administered by the Royal Court
Juan de Nova Island Juan de Nova Island the laws of France, where applicable, apply -
Kazakhstan Kazakhstan based on civil law system based on Islamic law and Roman law; has not accepted compulsory ICJ jurisdiction
Kenya 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 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
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 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 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; has not accepted compulsory ICJ jurisdiction
Kyrgyzstan Kyrgyzstan based on civil law system based on French and Russian laws; has not accepted compulsory ICJ jurisdiction
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; has not accepted compulsory ICJ jurisdiction
Latvia Latvia based on civil law system based on civil law system with traces of Socialist legal traditions and practices; 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; accepts compulsory ICJ jurisdiction with reservations
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; accepts compulsory ICJ jurisdiction with reservations
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 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
Liechtenstein Liechtenstein local civil and penal codes; accepts compulsory ICJ jurisdiction, with reservations local civil and penal codes based on civil law system; accepts compulsory ICJ jurisdiction with reservations
Lithuania Lithuania based on civil law system; legislative acts can be appealed to the constitutional court based on civil law system; legislative acts can be appealed to the constitutional court; has not accepted compulsory ICJ jurisdiction
Macedonia Macedonia - based on civil law system; judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
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; accepts compulsory ICJ jurisdiction with reservations
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; accepts compulsory ICJ jurisdiction with reservations
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; Islamic law is applied to Muslims in matters of family law and religion; 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; 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
Martinique Martinique French legal system -
Mauritania Mauritania a combination of Shari'a (Islamic law) and French civil law a combination of Islamic law and French civil law; has not accepted compulsory ICJ jurisdiction
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; accepts compulsory ICJ jurisdiction with reservations
Mayotte Mayotte French law the laws of France, where applicable, apply
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
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; accepts many UN and Organization for Security and Cooperation in Europe (OSCE) documents; 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
Montenegro Montenegro - based on civil law system; has not accepted compulsory ICJ jurisdiction
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 systems; judicial review of legislative acts in Constitutional Chamber of Supreme Court; has not accepted compulsory ICJ jurisdiction
Nauru Nauru acts of the Nauru Parliament and British common law acts of the Nauru Parliament and British common law; accepts compulsory ICJ jurisdiction with reservations
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 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
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 based on French civil law; the 1988 Matignon Accords grant substantial autonomy to the islands
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; accepts 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 law (in 12 northern states), and traditional law; accepts compulsory ICJ jurisdiction with reservations
Niue Niue English common law


note: Niue is self-governing, with the power to make its own laws
English common law; note - Niue is self-governing, with the power to make its own laws
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
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
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; has not accepted compulsory ICJ jurisdiction
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; accepts compulsory ICJ jurisdiction
Peru Peru based on civil law system; has not accepted compulsory ICJ jurisdiction based on civil law system; accepts compulsory ICJ jurisdiction with reservations
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
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 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 Portugal civil law system; the Constitutional Tribunal reviews the constitutionality of legislation; accepts compulsory ICJ jurisdiction, with reservations based on 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 and adapted US state laws 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 dominates family and personal matters 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
Reunion Reunion 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 based on civil law system; has not accepted compulsory ICJ jurisdiction
Russia Russia based on civil law system; judicial review of legislative acts based on civil law system; judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
Saint Barthelemy Saint Barthelemy - the laws of France, where applicable, apply
Saint Helena Saint Helena NA English common law and statutes, supplemented by local statutes
Saint Martin Saint Martin - the laws of France, where applicable, apply
Saint Pierre and Miquelon Saint Pierre and Miquelon French law with special adaptations for local conditions, such as housing and taxation the laws of France, where applicable, apply
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 Shari'a 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; accepts compulsory ICJ jurisdiction with reservations
Serbia Serbia - based on civil law system; has not accepted compulsory ICJ jurisdiction
Serbia and Montenegro Serbia and Montenegro based on civil law system -
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; 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 Slovenia based on civil law system based on civil law system; has not accepted compulsory ICJ jurisdiction
Somalia Somalia no national system; Shari'a and secular courts are in some localities no national system; a mixture of English common law, Italian law, Islamic Shari'a, and Somali customary law; accepts compulsory ICJ jurisdiction with reservations
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
Spain Spain civil law system, with regional applications; has not accepted compulsory ICJ jurisdiction civil law system, with regional applications; accepts compulsory ICJ jurisdiction with reservations
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, Islamic, 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; 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
Suriname Suriname based on Dutch legal system incorporating French penal theory based on Dutch legal system incorporating French penal theory; accepts compulsory ICJ jurisdiction with reservations
Svalbard Svalbard NA the laws of Norway, where applicable, apply
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; accepts compulsory ICJ jurisdiction with reservations
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 a combination of French and Ottoman civil law; Islamic law is used in the family court system; has not accepted compulsory ICJ jurisdiction
Taiwan Taiwan based on civil law system; accepts compulsory ICJ jurisdiction, with reservations based on civil law system; has not accepted compulsory ICJ jurisdiction
Tajikistan Tajikistan based on civil law system; no judicial review of legislative acts based on civil law system; no judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
Timor-Leste Timor-Leste - UN-drafted legal system based on Indonesian law remains in place but are to be replaced by civil and penal codes based on Portuguese law; these have passed but have not been promulgated; has not accepted compulsury ICJ jurisdiction
Togo Togo French-based court system French-based court system; accepts compulsory ICJ jurisdiction, with reservations
Tonga Tonga based on English law based on English common law
Tromelin Island Tromelin Island 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; has not accepted compulsory ICJ jurisdiction
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; 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
Turkmenistan Turkmenistan based on civil law system based on civil law system and Islamic law; has not accepted compulsory ICJ jurisdiction
Ukraine Ukraine based on civil law system; judicial review of legislative acts based on civil law system; judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
United Arab Emirates United Arab Emirates federal court system introduced in 1971; all emirates except Dubayy (Dubai) and Ra's al Khaymah are not fully integrated into the federal system; all emirates have secular and Islamic law for civil, criminal, and high courts based on a dual system of Shari'a and civil courts; has not accepted compulsory ICJ jurisdiction
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 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
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, 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
United States Pacific Island Wildlife Refuges United States Pacific Island Wildlife Refuges - the laws of the US, where applicable, apply
Uzbekistan Uzbekistan evolution of Soviet civil law; still lacks independent judicial system based on civil law system; has not accepted compulsory ICJ jurisdiction
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 has not accepted compulsory ICJ jurisdiction
Wallis and Futuna Wallis and Futuna French legal system the laws of France, where applicable, apply
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
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