Compare Legal system (2005) - Legal system (2002)

Compare Legal system (2005) with Legal system (2002)

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	Legal system (2005)	Legal system (2002)
Afghanistan	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	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
Akrotiri	the laws of the UK, where applicable, apply	-
Albania	has a civil law system; has not accepted compulsory ICJ jurisdiction; has accepted jurisdiction of the International Criminal Court for its citizens	has not accepted compulsory ICJ jurisdiction
Antarctica	Antarctica is administered through meetings of the consultative member nations; decisions from these meetings are carried out by these member nations (with respect to their own nationals and operations) in accordance with their own national laws; US law, including certain criminal offenses by or against US nationals, such as murder, may apply 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.	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.
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 with the final stage of implementation in the Santiago metropolitan region expected in June 2005	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
Colombia	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	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
Comoros	French and Sharia (Islamic) law in a new consolidated code	French and Muslim law in a new consolidated code
Dhekelia	the laws of the UK, where applicable, apply	-
Dominican Republic	based on French civil codes; undergoing modification in 2004 towards an accusatory system	based on French civil codes
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)	NA
Finland	civil law system based on Swedish law; the president may request the Supreme Court to review laws; accepts compulsory ICJ jurisdiction, with reservations	civil law system based on Swedish law; Supreme Court may request legislation interpreting or modifying laws; accepts compulsory ICJ jurisdiction, with reservations
Guernsey	English law and local statutes; justice is administered by the Royal Court	English law and local statute; justice is administered by the Royal Court
Holy See (Vatican City)	based on Code of Canon Law and revisions to it	based on canon law and revisions to it
India	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	based on English common law; limited judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations
Indonesia	based on Roman-Dutch law, substantially modified by indigenous concepts and by new criminal procedures and election codes; has not accepted compulsory ICJ jurisdiction	based on Roman-Dutch law, substantially modified by indigenous concepts and by new criminal procedures code; has not accepted compulsory ICJ jurisdiction
Iraq	based on civil and Islamic law under the Iraqi Interim Government (IG) and Transitional Administrative Law (TAL)	based on Islamic law in special religious courts, civil law system elsewhere; has not accepted compulsory ICJ jurisdiction
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
Jersey	English law and local statute; justice is administered by the Royal Court	English law and local statute
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
Macedonia	based on civil law system; judicial review of legislative acts	-
Macedonia, The Former Yugoslav Republic of	-	based on civil law system; judicial review of legislative acts
Mongolia	blend of Soviet, German, and US systems that combine "continental" or "civil" code and case-precedent; constitution ambiguous on judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction	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
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 Zealand	based on English law, with special land legislation and land courts for the Maori; accepts compulsory ICJ jurisdiction with reservations	based on English law, with special land legislation and land courts for Maoris; accepts compulsory ICJ jurisdiction, with reservations
Nigeria	based on English common law, Islamic Shariah law (in 12 northern states), and traditional law	based on English common law, Islamic Shariah law (only in some northern states), and traditional law
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 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
Puerto Rico	based on Spanish civil code and within the US Federal system of justice	based on Spanish civil code and adapted US state laws
Turkey	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	derived from various European continental legal systems; accepts compulsory ICJ jurisdiction, with reservations
United Arab Emirates	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	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
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; 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
United States	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	based on English common law; judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations
Venezuela	open, adversarial court system	based on organic laws as of July 1999; open, adversarial court system; has not accepted compulsory ICJ jurisdiction
World	all members of the UN are parties to the statute that established the International Court of Justice (ICJ) or World Court	all members of the UN plus Switzerland are parties to the statute that established the International Court of Justice (ICJ) or World Court