Compare Legal system (2008) - Legal system (2001)

Compare Legal system (2008) with Legal system (2001)

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	Legal system (2008)	Legal system (2001)
Afghanistan	based on mixed civil and Shari'a law; has not accepted compulsory ICJ jurisdiction	a new legal system has not been adopted but all factions tacitly agree they will follow Shari'a (Islamic law)
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	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
Angola	based on Portuguese civil law system and customary law; modified to accommodate political pluralism and increased use of free markets	based on Portuguese civil law system and customary law; recently modified to accommodate political pluralism and increased use of free markets
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 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	Antarctica is administered through meetings of the consultative member nations. Decisions from these meetings are carried out by these member nations (within their areas) in accordance with their own national laws. US law, including certain criminal offenses by or against US nationals, such as murder, may apply extra-territorially. Some US laws directly apply to Antarctica. For example, the Antarctic Conservation Act, 16 U.S.C. section 2401 et seq., provides civil and criminal penalties for the following activities, unless authorized by regulation of statute: the taking of native mammals or birds; the introduction of nonindigenous plants and animals; entry into specially protected areas; the discharge or disposal of pollutants; and the importation into the US of certain items from Antarctica. Violation of the Antarctic Conservation Act carries penalties of up to $10,000 in fines and one year in prison. The National Science Foundation and Department of Justice share enforcement responsibilities. Public Law 95-541, the US Antarctic Conservation Act of 1978, as amended in 1996, requires expeditions from the US to Antarctica to notify, in advance, the Office of Oceans and Polar Affairs, Room 5801, Department of State, Washington, DC 20520, which reports such plans to other nations as required by the Antarctic Treaty. For more information, contact Permit Office, Office of Polar Programs, National Science Foundation, Arlington, Virginia 22230; telephone: (703) 292-8030, or see their website at www.nsf.gov.
Armenia	based on civil law system; has not accepted compulsory ICJ jurisdiction	based on civil law system
Ashmore and Cartier Islands	the laws of the Commonwealth of Australia and the laws of the Northern Territory of Australia, where applicable, apply	the laws of the Northern Territory of Australia, where applicable, apply
Austria	civil law system with Roman law origin; judicial review of legislative acts by the Constitutional Court; separate administrative and civil/penal supreme courts; accepts compulsory ICJ jurisdiction	civil law system with Roman law origin; judicial review of legislative acts by the Constitutional Court; separate administrative and civil/penal supreme courts; has not accepted compulsory ICJ jurisdiction
Azerbaijan	based on civil law system; has not accepted compulsory ICJ jurisdiction	based on civil law system
Bahrain	based on Islamic law and English common law; has not accepted compulsory ICJ jurisdiction	based on Islamic law and English common law
Bangladesh	based on English common law; has not accepted compulsory ICJ jurisdiction	based on English common law
Barbados	English common law; no judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations	English common law; no judicial review of legislative acts
Bassas da India	-	the laws of France, where applicable, apply
Belarus	based on civil law system; has not accepted compulsory ICJ jurisdiction	based on civil law system
Belgium	based on civil law system influenced by English constitutional theory; judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations	civil law system influenced by English constitutional theory; judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations
Bosnia and Herzegovina	based on civil law system; has not accepted compulsory ICJ jurisdiction	based on civil law system
Botswana	based on Roman-Dutch law and local customary law; judicial review limited to matters of interpretation; accepts compulsory ICJ jurisdiction, with reservations	based on Roman-Dutch law and local customary law; judicial review limited to matters of interpretation; 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; has not accepted compulsory ICJ jurisdiction	based on English common law; for Muslims, Islamic Shari'a law supersedes civil law in a number of areas
Bulgaria	civil law and criminal law based on Roman law; accepts compulsory ICJ jurisdiction with reservations	civil law and criminal law based on Roman law; accepts compulsory ICJ jurisdiction
Burkina Faso	based on French civil law system and customary law; has not accepted compulsory ICJ jurisdiction	based on French civil law system and customary law
Burma	based on English common law; has not accepted compulsory ICJ jurisdiction	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; 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 in recent years
Cameroon	based on French civil law system, with common law influence; accepts compulsory ICJ jurisdiction	based on French civil law system, with common law influence; has not accepted compulsory ICJ jurisdiction
Cape Verde	based on the legal system of Portugal; has not accepted compulsory ICJ jurisdiction	derived from the legal system of Portugal
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 - in June 2005, Chile completed overhaul of its criminal justice system to a new, US-style adversarial system	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
China	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	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
Colombia	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	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 Islamic law in a new consolidated code	French and Muslim law in a new consolidated code
Congo, Democratic Republic of the	a new constitution was adopted by referendum 18 December 2005; accepts compulsory ICJ jurisdiction, with reservations	based on Belgian civil law system and tribal law; has not accepted compulsory ICJ jurisdiction
Cote d'Ivoire	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	based on French civil law system and customary law; judicial review in the Constitutional Chamber of the Supreme Court; has not accepted compulsory ICJ jurisdiction
Croatia	based on Austro-Hungarian law system with Communist law influences; has not accepted compulsory ICJ jurisdiction	based on civil law system
Cuba	based on Spanish civil law and influenced by American legal concepts, with large elements of Communist legal theory; has not accepted compulsory ICJ jurisdiction	based on Spanish and American law, with large elements of Communist legal theory; has not accepted compulsory ICJ jurisdiction
Cyprus	based on English common law, with civil law modifications; accepts compulsory ICJ jurisdiction, with reservations	based on common law, with civil law modifications
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	based on French civil law system, traditional practices, and Islamic law; accepts ICJ jurisdiction, with reservations	based on French civil law system, traditional practices, and Islamic law
Dominican Republic	based on French civil codes; Criminal Procedures Code modified in 2004 to include important elements of an accusatory system; accepts compulsory ICJ jurisdiction	based on French civil codes
Egypt	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	based on English common law, Islamic law, and Napoleonic codes; judicial review by Supreme Court and Council of State (oversees validity of administrative decisions); accepts compulsory ICJ jurisdiction, with reservations
El Salvador	based on civil and Roman law with traces of common law; judicial review of legislative acts in the Supreme Court	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
Eritrea	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	operates on the basis of transitional laws that incorporate pre-independence statutes of the Eritrean People's Liberation Front, revised Ethiopian laws, customary laws, and post independence enacted laws
Estonia	based on civil law system; accepts compulsory ICJ jurisdiction with reservations	based on civil law system; no judicial review of legislative acts
Ethiopia	based on civil law; currently transitional mix of national and regional courts; has not accepted compulsory ICJ jurisdiction	currently transitional mix of national and regional courts
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	the laws of Denmark, where applicable, apply	Danish
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
France	civil law system with indigenous concepts; review of administrative but not legislative acts; has not accepted compulsory ICJ jurisdiction	civil law system with indigenous concepts; review of administrative but not legislative acts
French Guiana	-	French legal system
French Polynesia	the laws of France, where applicable, apply	based on French system
Gambia, The	based on a composite of English common law, Islamic law, and customary law; accepts compulsory ICJ jurisdiction with reservations	based on a composite of English common law, Koranic law, and customary law; accepts compulsory ICJ jurisdiction, with reservations
Georgia	based on civil law system; accepts compulsory ICJ jurisdiction	based on civil law system
Gibraltar	the laws of the UK, where applicable, apply	English law
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
Greenland	the laws of Denmark, where applicable, apply	Danish
Guadeloupe	-	French legal system
Guernsey	the laws of the UK, where applicable, apply; justice is administered by the Royal Court	English law and local statute; justice is administered by the Royal Court
Guinea	based on French civil law system, customary law, and decree; accepts compulsory ICJ jurisdiction with reservations	based on French civil law system, customary law, and decree; legal codes currently being revised; has not accepted compulsory ICJ jurisdiction
Guinea-Bissau	based on French civil law; accepts compulsory ICJ jurisdiction	NA
Holy See (Vatican City)	based on Code of Canon Law and revisions to it	NA
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	based German-Austrian legal system; accepts compulsory ICJ jurisdiction with reservations	rule of law based on Western model
India	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	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
Iran	based on Sharia law system; has not accepted compulsory ICJ jurisdiction	the Constitution codifies Islamic principles of government
Iraq	based on European civil and Islamic law under the framework outlined in the Iraqi Constitution; has not accepted compulsory ICJ jurisdiction	based on Islamic law in special religious courts, civil law system elsewhere; has not accepted compulsory ICJ jurisdiction
Isle of Man	the laws of the UK, where applicable, apply and Manx statutes	English common law and Manx statute
Japan	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	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	the laws of the UK, where applicable, apply and local statutes; justice is administered by the Royal Court	English law and local statute
Juan de Nova Island	-	the laws of France, where applicable, apply
Kazakhstan	based on Islamic law and Roman law; has not accepted compulsory ICJ jurisdiction	based on civil law system
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 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 Prussian civil law system with Japanese influences and Communist legal theory; no judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction	based on German civil law system with Japanese influences and Communist legal theory; no judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
Korea, South	combines elements of continental European civil law systems, Anglo-American law, and Chinese classical thought; has not accepted compulsory ICJ jurisdiction	combines elements of continental European civil law systems, Anglo-American law, and Chinese classical thought
Kosovo	evolving legal system based on terms of UN Special Envoy Martii AHTISAARI's Plan for Kosovo's supervised independence	-
Kyrgyzstan	based on French and Russian laws; has not accepted compulsory ICJ jurisdiction	based on civil law system
Laos	based on traditional customs, French legal norms and procedures, and socialist practice; has not accepted compulsory ICJ jurisdiction	based on traditional customs, French legal norms and procedures, and Socialist practice
Latvia	based on civil law system with traces of Socialist legal traditions and practices; has not accepted compulsory ICJ jurisdiction	based on civil law system
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; has not accepted compulsory ICJ jurisdiction
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
Libya	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	based on Italian civil law system and Islamic law; separate religious courts; no constitutional provision for judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
Liechtenstein	local civil and penal codes based on civil law system; accepts compulsory ICJ jurisdiction with reservations	local civil and penal codes; accepts compulsory ICJ jurisdiction, with reservations
Lithuania	based on civil law system; legislative acts can be appealed to the constitutional court; has not accepted compulsory ICJ jurisdiction	based on civil law system; no judicial review of legislative acts
Macedonia	based on civil law system; judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction	-
Macedonia, The Former Yugoslav Republic of	-	based on civil law system; judicial review of legislative acts
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; has not accepted compulsory ICJ jurisdiction
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; has not accepted compulsory ICJ jurisdiction
Malaysia	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	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
Mali	based on French civil law system and customary law; judicial review of legislative acts in Constitutional Court; has not accepted compulsory ICJ jurisdiction	based on French civil law system and customary law; judicial review of legislative acts in Constitutional Court (which was formally established on 9 March 1994); has not accepted compulsory ICJ jurisdiction
Malta	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 Islamic law and French civil law; has not accepted compulsory ICJ jurisdiction	a combination of Shari'a (Islamic law) and French civil law
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
Mayotte	the laws of France, where applicable, apply	French law
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; has not accepted compulsory ICJ jurisdiction	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
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
Montenegro	based on civil law system; has not accepted compulsory ICJ jurisdiction	-
Morocco	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	based on Islamic law and French and Spanish civil law system; judicial review of legislative acts in Constitutional Chamber of Supreme Court
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
Netherlands	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	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	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	based on French civil law; the 1988 Matignon Accords grant substantial autonomy to the islands	the 1988 Matignon Accords grant substantial autonomy to the islands; formerly under French law
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
Nicaragua	civil law system; Supreme Court may review administrative acts; accepts compulsory ICJ jurisdiction	civil law system; Supreme Court may review administrative acts
Nigeria	based on English common law, Islamic law (in 12 northern states), and traditional law; accepts compulsory ICJ jurisdiction with reservations	based on English common law, Islamic Shariah law (only in some northern states), and traditional law
Niue	English common law; note - Niue is self-governing, with the power to make its own laws	English common law
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; has not accepted compulsory ICJ jurisdiction	based on English common law
Paraguay	based on Argentine codes, Roman law, and French codes; judicial review of legislative acts in Supreme Court of Justice; accepts compulsory ICJ jurisdiction	based on Argentine codes, Roman law, and French codes; judicial review of legislative acts in Supreme Court of Justice
Peru	based on civil law system; accepts compulsory ICJ jurisdiction with reservations	based on civil law system; has not accepted compulsory ICJ jurisdiction
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	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	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
Portugal	based on civil law system; the Constitutional Tribunal reviews the constitutionality of legislation; accepts compulsory ICJ jurisdiction with reservations	civil law system; the Constitutional Tribunal reviews the constitutionality of legislation; accepts compulsory ICJ jurisdiction, with reservations
Puerto Rico	based on Spanish civil code and within the US Federal system of justice	based on Spanish civil code
Qatar	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	discretionary system of law controlled by the amir, although civil codes are being implemented; Islamic law is significant in personal matters
Reunion	-	French law
Romania	based on civil law system; has not accepted compulsory ICJ jurisdiction	former mixture of civil law system and communist legal theory; is now based on the constitution of France's Fifth Republic
Russia	based on civil law system; judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction	based on civil law system; judicial review of legislative acts
Saint Barthelemy	the laws of France, where applicable, apply	-
Saint Helena	English common law and statutes, supplemented by local statutes	NA
Saint Martin	the laws of France, where applicable, apply	-
Saint Pierre and Miquelon	the laws of France, where applicable, apply	French law with special adaptations for local conditions, such as housing and taxation
Saudi Arabia	based on Shari'a law, several secular codes have been introduced; commercial disputes handled by special committees; has not accepted compulsory ICJ jurisdiction	based on Islamic law, several secular codes have been introduced; commercial disputes handled by special committees; has not accepted compulsory ICJ jurisdiction
Senegal	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; has not accepted compulsory ICJ jurisdiction
Serbia	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; has not accepted compulsory ICJ jurisdiction; legal code modified to comply with the obligations of Organization on Security and Cooperation in Europe (OSCE) and to expunge Marxist-Leninist legal theory
Slovenia	based on civil law system; has not accepted compulsory ICJ jurisdiction	based on civil law system
Solomon Islands	English common law, which is widely disregarded	English common law
Somalia	no national system; a mixture of English common law, Italian law, Islamic Shari'a, and Somali customary law; accepts compulsory ICJ jurisdiction with reservations	NA
South Africa	based on Roman-Dutch law and English common law	based on Roman-Dutch law and English common law; accepts compulsory ICJ jurisdiction, with reservations
South Georgia and the South Sandwich Islands	the laws of the UK, where applicable, apply; the senior magistrate from the Falkland Islands presides over the Magistrates Court	the laws of the UK, where applicable, apply
Spain	civil law system, with regional applications; accepts compulsory ICJ jurisdiction with reservations	civil law system, with regional applications; has not accepted compulsory ICJ jurisdiction
Sri Lanka	a highly complex mixture of English common law, Roman-Dutch, Kandyan, and Jaffna Tamil law; has not accepted compulsory ICJ jurisdiction	a highly complex mixture of English common law, Roman-Dutch, Muslim, Sinhalese, and customary law; has not accepted compulsory ICJ jurisdiction
Sudan	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	based on English common law and Islamic law; as of 20 January 1991, the now defunct Revolutionary Command Council imposed Islamic law in the northern states; Islamic law applies to all residents of the northern states regardless of their religion; some separate religious courts; accepts compulsory ICJ jurisdiction, with reservations
Suriname	based on Dutch legal system incorporating French penal theory; accepts compulsory ICJ jurisdiction with reservations	based on Dutch legal system incorporating French penal theory
Svalbard	the laws of Norway, where applicable, apply	NA
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; has not accepted compulsory ICJ jurisdiction
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; Islamic law is used in the family court system; has not accepted compulsory ICJ jurisdiction	based on Islamic law and civil law system; special religious courts; has not accepted compulsory ICJ jurisdiction
Taiwan	based on civil law system; has not accepted compulsory ICJ jurisdiction	based on civil law system; accepts compulsory ICJ jurisdiction, with reservations
Tajikistan	based on civil law system; no judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction	based on civil law system; no judicial review of legislative acts
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	-
Togo	French-based court system; accepts compulsory ICJ jurisdiction, with reservations	French-based court system
Tokelau	New Zealand and local statutes	British and local statutes
Tonga	based on English common law	based on English law
Tromelin Island	-	the laws of France, where applicable, apply
Tunisia	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	based on French civil law system and Islamic law; some judicial review of legislative acts in the Supreme Court in joint session
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; has not accepted compulsory ICJ jurisdiction	derived from various European continental legal systems; accepts compulsory ICJ jurisdiction, with reservations
Turkmenistan	based on civil law system and Islamic law; has not accepted compulsory ICJ jurisdiction	based on civil law system
Turks and Caicos Islands	based on laws of England and Wales, with a few adopted from Jamaica and The Bahamas	based on laws of England and Wales, with a small number adopted from Jamaica and The Bahamas
Ukraine	based on civil law system; judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction	based on civil law system; judicial review of legislative acts
United Arab Emirates	based on a dual system of Shari'a and civil courts; has not accepted compulsory ICJ jurisdiction	federal court system introduced in 1971; all emirates except Dubayy (Dubai) and Ra's al Khaymah have joined the federal system; all emirates have secular and Islamic law for civil, criminal, and high courts
United Kingdom	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	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, 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	based on English common law; judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations
United States Pacific Island Wildlife Refuges	the laws of the US, where applicable, apply	-
Uzbekistan	based on civil law system; has not accepted compulsory ICJ jurisdiction	evolution of Soviet civil law; still lacks independent judicial system
Venezuela	open, adversarial court system	based on organic laws as of July 1999; open, adversarial court system; has not accepted compulsory ICJ jurisdiction
Vietnam	based on communist legal theory and French civil law system has not accepted compulsory ICJ jurisdiction	based on communist legal theory and French civil law system
Wallis and Futuna	the laws of France, where applicable, apply	French legal system
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
Yugoslavia	-	based on civil law system