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  Legal system (2003)Legal system (2006)
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 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
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
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
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
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; 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
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
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
Cyprus Cyprus based on common law, with civil law modifications based on common law, with civil law modifications; accepts compulsory ICJ jurisdiction, with reservations
Dhekelia Dhekelia - the laws of the UK, where applicable, apply
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 UN-drafted legal system based on Indonesian law (2002) UN-drafted legal system based on Indonesian law remains in place but will be replaced by civil and penal codes based on Portuguese law; these have passed and are expected to be promulgated in early 2006
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
Estonia Estonia based on civil law system; no judicial review of legislative acts based on civil law system; no judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations
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
Georgia Georgia based on civil law system based on civil law system; accepts compulsory ICJ jurisdiction
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
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; accepts compulsory ICJ jurisdiction, with reservations
Guinea-Bissau Guinea-Bissau NA accepts compulsory ICJ jurisdiction
Hungary Hungary rule of law based on Western model rule of law based on Western model; accepts compulsory ICJ jurisdiction, with reservations
Iles Eparses Iles Eparses - the laws of France, where applicable, apply
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
Iraq Iraq in transition following April 2003 defeat of SADDAM Husayn regime by US-led coalition based on European civil and Islamic law under the framework outlined in the Iraqi Constitution
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
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; 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; has not accepted compulsory ICJ jurisdiction; Islamic law is applied to Muslims in matters of family 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; 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
Mongolia Mongolia blend of Soviet, German, and US 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
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 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
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 Shariah 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
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
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, but rulings of the Constitutional Tribunal are final; 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; accepts compulsory ICJ jurisdiction, with reservations
Qatar Qatar discretionary system of law controlled by the amir, although civil codes are being implemented; Islamic law dominates family and personal matters discretionary system of law controlled by the amir, although civil codes are being implemented; Shari'a law dominates family and personal matters
Saint Helena Saint Helena NA British common law and statutes, supplemented by local statutes
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
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
Somalia Somalia no national system; Shari'a and secular courts are in some localities no national system; Shari'a (Islamic) and secular courts based on Somali customary law (xeer) are present in some localities; 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
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 Shari'a law; as of 20 January 1991, the now defunct Revolutionary Command Council imposed Shari'a law in the northern states; Shari'a law applies to all residents of the northern states regardless of their religion; some separate religious courts; accepts compulsory ICJ jurisdiction, with reservations; the southern legal system is still developing under the CPA following the civil war; Shari'a 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
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
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; religious 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
Togo Togo French-based court system French-based court system; accepts compulsory ICJ jurisdiction, with reservations
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 Shari'a 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; note - member of the European Court of Human Rights (ECHR), although Turkey claims limited derogations on the ratified European Convention on Human Rights
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 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 judicial 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; has judicial review of Acts of Parliament under the Human Rights Act of 1998; accepts compulsory ICJ jurisdiction, with reservations 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's) is based on English common law; judicial review of legislative acts
United States Pacific Island Wildlife Refuges United States Pacific Island Wildlife Refuges - the laws of the US, where applicable, apply
Venezuela Venezuela based on organic laws as of July 1999; open, adversarial court system; has not accepted compulsory ICJ jurisdiction open, adversarial court 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
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