Compare Legal system (2006) - Legal system (2008)

Compare Legal system (2006) with Legal system (2008)

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	Legal system (2006)	Legal system (2008)
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	based on mixed civil and Shari'a law; has not accepted compulsory ICJ jurisdiction
Akrotiri	the laws of the UK, where applicable, apply	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
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; modified to accommodate political pluralism and increased use of free markets
Armenia	based on civil law system	based on civil law system; has not accepted compulsory ICJ jurisdiction
Azerbaijan	based on civil law system	based on civil law system; has not accepted compulsory ICJ jurisdiction
Bahrain	based on Islamic law and English common law	based on Islamic law and English common law; has not accepted compulsory ICJ jurisdiction
Bangladesh	based on English common law	based on English common law; has not accepted compulsory ICJ jurisdiction
Bassas da India	the laws of France, where applicable, apply	-
Belarus	based on civil law system	based on civil law system; has not accepted compulsory ICJ jurisdiction
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	based on civil law system	based on civil law system; has not accepted compulsory ICJ jurisdiction
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	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	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	has not accepted compulsory ICJ jurisdiction	based on English common law; has not accepted compulsory ICJ jurisdiction
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; accepts compulsory ICJ jurisdiction, with reservations	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
Cape Verde	derived from the legal system of Portugal	based on the legal system of Portugal; has not accepted compulsory ICJ jurisdiction
Comoros	French and Sharia (Islamic) law in a new consolidated code	French and Islamic law in a new consolidated code
Croatia	based on civil law system	based on Austro-Hungarian law system with Communist law influences; has not accepted compulsory ICJ jurisdiction
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	based on common law, with civil law modifications; accepts compulsory ICJ jurisdiction, with reservations	based on English common law, with civil law modifications; accepts compulsory ICJ jurisdiction, with reservations
Dhekelia	the laws of the UK, where applicable, apply	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	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
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; these have passed and are expected to be promulgated in early 2006	-
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
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	based on civil law system; no judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations	based on civil law system; accepts compulsory ICJ jurisdiction with reservations
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	the laws of France, where applicable, apply	-
European Union	-	comparable to the legal systems of member states; first supranational law system
Faroe Islands	Danish	the laws of Denmark, where applicable, apply
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; the president may request the Supreme Court to review laws; accepts compulsory ICJ jurisdiction with reservations
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 legal system	-
French Polynesia	based on French system	the laws of France, where applicable, apply
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
Gibraltar	English law	the laws of the UK, where applicable, apply
Glorioso Islands	the laws of France, where applicable, apply	-
Greece	based on codified Roman law; judiciary divided into civil, criminal, and administrative courts; accepts compulsory ICJ jurisdiction, with reservations	based on codified Roman law; judiciary divided into civil, criminal, and administrative courts; accepts compulsory ICJ jurisdiction with reservations
Greenland	Danish	the laws of Denmark, where applicable, apply
Guadeloupe	French legal system	-
Guernsey	English law and local statutes; justice is administered by the Royal Court	the laws of the UK, where applicable, apply; justice is administered by the Royal Court
Guinea	based on French civil law system, customary law, and decree; legal codes currently being revised; accepts compulsory ICJ jurisdiction, with reservations	based on French civil law system, customary law, and decree; accepts compulsory ICJ jurisdiction with reservations
Guinea-Bissau	accepts compulsory ICJ jurisdiction	based on French civil law; accepts compulsory ICJ jurisdiction
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	rule of law based on Western model; accepts compulsory ICJ jurisdiction, with reservations	based German-Austrian legal system; accepts compulsory ICJ jurisdiction with reservations
Iles Eparses	the laws of France, where applicable, apply	-
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; judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations; separate personal law codes apply to Muslims, Christians, and Hindus
Iran	the Constitution codifies Islamic principles of government	based on Sharia law system; has not accepted compulsory ICJ jurisdiction
Iraq	based on European civil and Islamic law under the framework outlined in the Iraqi Constitution	based on European civil and Islamic law under the framework outlined in the Iraqi Constitution; has not accepted compulsory ICJ jurisdiction
Isle of Man	English common law and Manx statute	the laws of the UK, where applicable, apply and Manx statutes
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	English law and local statute; justice is administered by the Royal Court	the laws of the UK, where applicable, apply and local statutes; justice is administered by the Royal Court
Juan de Nova Island	the laws of France, where applicable, apply	-
Kazakhstan	based on civil law system	based on Islamic law and Roman law; has not accepted compulsory ICJ jurisdiction
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	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	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
Kosovo	-	evolving legal system based on terms of UN Special Envoy Martii AHTISAARI's Plan for Kosovo's supervised independence
Kyrgyzstan	based on civil law system	based on French and Russian laws; has not accepted compulsory ICJ jurisdiction
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	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	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	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	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	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	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	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	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	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
Madagascar	based on French civil law system and traditional Malagasy law; accepts compulsory ICJ jurisdiction, with reservations	based on French civil law system and traditional Malagasy law; accepts compulsory ICJ jurisdiction with reservations
Malawi	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	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	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	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	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	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	French legal system	-
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	based on French civil law system with elements of English common law in certain areas; accepts compulsory ICJ jurisdiction, with reservations	based on French civil law system with elements of English common law in certain areas; accepts compulsory ICJ jurisdiction with reservations
Mayotte	French law	the laws of France, where applicable, apply
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	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	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
Montenegro	based on civil law system	based on civil law system; has not accepted compulsory ICJ jurisdiction
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	acts of the Nauru Parliament and British common law; accepts compulsory ICJ jurisdiction, with reservations	acts of the Nauru Parliament and British common law; accepts compulsory ICJ jurisdiction with reservations
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
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	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 the Maori; accepts compulsory ICJ jurisdiction with reservations
Nigeria	based on English common law, Islamic Shariah law (in 12 northern states), and traditional law; accepts compulsory ICJ jurisdiction, with reservations	based on English common law, Islamic law (in 12 northern states), and traditional law; accepts compulsory ICJ jurisdiction with reservations
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	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	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	based on English common law	based on English common law; has not accepted compulsory ICJ jurisdiction
Peru	based on civil law system; accepts compulsory ICJ jurisdiction, with reservations	based on civil law system; accepts compulsory ICJ jurisdiction with reservations
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	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	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	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
Qatar	discretionary system of law controlled by the amir, although civil codes are being implemented; Shari'a 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	French law	-
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	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	-	the laws of France, where applicable, apply
Saint Helena	British common law and statutes, supplemented by local statutes	English common law and statutes, supplemented by local statutes
Saint Martin	-	the laws of France, where applicable, apply
Saint Pierre and Miquelon	French law with special adaptations for local conditions, such as housing and taxation	the laws of France, where applicable, apply
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; accepts compulsory ICJ jurisdiction, with reservations	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	based on civil law system	based on civil law system; has not accepted compulsory ICJ jurisdiction
Slovakia	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	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	based on civil law system	based on civil law system; has not accepted compulsory ICJ jurisdiction
Somalia	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	no national system; a mixture of English common law, Italian law, Islamic Shari'a, and Somali customary law; accepts compulsory ICJ jurisdiction with reservations
Spain	civil law system, with regional applications; accepts compulsory ICJ jurisdiction, with reservations	civil law system, with regional applications; accepts compulsory ICJ jurisdiction with reservations
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, Kandyan, and Jaffna Tamil law; has not accepted compulsory ICJ jurisdiction
Sudan	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	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	based on Dutch legal system incorporating French penal theory; accepts compulsory ICJ jurisdiction, with reservations	based on Dutch legal system incorporating French penal theory; accepts compulsory ICJ jurisdiction with reservations
Svalbard	NA	the laws of Norway, where applicable, apply
Swaziland	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	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	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	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	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	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	based on civil law system	based on civil law system; has not accepted compulsory ICJ jurisdiction
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	-	UN-drafted legal system based on Indonesian law remains in place but is to be replaced by civil and penal codes based on Portuguese law; these have passed but have not been promulgated; has not accepted compulsory ICJ jurisdiction
Tonga	based on English law	based on English common law
Tromelin Island	the laws of France, where applicable, apply	-
Tunisia	based on French civil law system and Shari'a 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	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	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	based on civil law system	based on civil law system and Islamic law; has not accepted compulsory ICJ jurisdiction
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	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	based on a dual system of Shari'a and civil courts; has not accepted compulsory ICJ jurisdiction
United Kingdom	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	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	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	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
Uzbekistan	evolution of Soviet civil law; still lacks independent judicial system	based on civil law system; has not accepted compulsory ICJ jurisdiction
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	French legal system	the laws of France, where applicable, apply