based on English common law; has not accepted compulsory ICJ
jurisdiction
Burundi
based on German and Belgian civil codes and customary 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; accepts compulsory ICJ jurisdiction with
reservations
Cameroon
based on French civil law system, with common law
influence; accepts compulsory ICJ jurisdiction
Canada
based on English common law, except in Quebec, where civil
law system based on French law prevails; accepts compulsory ICJ
jurisdiction with reservations
Cape Verde
based on the legal system of Portugal; has not accepted
compulsory ICJ jurisdiction
Cayman Islands
British common law and local statutes
Central African Republic
based on French law; has not accepted
compulsory ICJ jurisdiction
Chad
based on French civil law system and Chadian customary law; has
not accepted compulsory ICJ jurisdiction
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
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
Christmas Island
under the authority of the governor general of
Australia and Australian law
Clipperton Island
the laws of France, where applicable, apply
Cocos (Keeling) Islands
based upon the laws of Australia and local
laws
Colombia
based on Spanish law; a new criminal code modeled after US
procedures was enacted into law in 2004 and reached full
implementation in January 2008; judicial review of executive and
legislative acts; has not accepted compulsory ICJ jurisdiction
Comoros
French and Islamic law in a new consolidated code; has not
accepted compulsory ICJ jurisdiction
Congo, Democratic Republic of the
civil law based on Belgian law
with Napleonic Civil Code influence; accepts compulsory ICJ
jurisdiction with reservations
Congo, Republic of the
based on French civil law system and
customary law; has not accepted compulsory ICJ jurisdiction
Cook Islands
based on New Zealand law and English common law
Coral Sea Islands
the laws of Australia, where applicable, apply
Costa Rica
based on Spanish civil law system; judicial review of
legislative acts in the Supreme Court; has 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
Croatia
based on Austro-Hungarian law system with Communist law
influences; has not accepted compulsory ICJ jurisdiction
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
Cyprus
based on English common law, with civil law modifications;
accepts compulsory ICJ jurisdiction with reservations
Czech Republic
civil law system based on Austro-Hungarian codes;
legal code modified to bring it in line with Organization on
Security and Cooperation in Europe (OSCE) obligations and to expunge
Marxist-Leninist legal theory
Denmark
civil law system; judicial review of legislative acts;
accepts compulsory ICJ jurisdiction with reservations
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
Dominica
based on English common law; accepts ICJ jurisdiction
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
Ecuador
based on civil law system; has not accepted compulsory ICJ
jurisdiction
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
El Salvador
based on civil and Roman law with traces of common law;
judicial review of legislative acts in the Supreme Court; has not
accepted compulsory ICJ jurisdiction
Equatorial Guinea
partly based on Spanish civil law and tribal
custom; has not accepted compulsory ICJ jurisdiction
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
Estonia
based on civil law system; accepts compulsory ICJ
jurisdiction with reservations
Ethiopia
based on civil law; currently transitional mix of national
and regional courts; has not accepted compulsory ICJ jurisdiction
European Union
comparable to the legal systems of member states;
first supranational law system
Falkland Islands (Islas Malvinas)
English common law
Faroe Islands
the laws of Denmark, where applicable, apply
Fiji
based on British system; has not accepted compulsory ICJ
jurisdiction
Finland
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; has not accepted compulsory
ICJ jurisdiction
French Polynesia
the laws of France, where applicable, apply
French Southern and Antarctic Lands
the laws of France, where
applicable, apply
Gabon
based on French civil law system and customary law; judicial
review of legislative acts in Constitutional Chamber of the Supreme
Court; has not accepted compulsory ICJ jurisdiction
Gambia, The
based on a composite of English common law, Islamic law,
and customary law; accepts compulsory ICJ jurisdiction with
reservations
Georgia
based on civil law system; accepts compulsory ICJ
jurisdiction
Germany
civil law system with indigenous concepts; judicial review
of legislative acts in the Federal Constitutional Court; has not
accepted compulsory ICJ jurisdiction
Ghana
based on English common law and customary law; has not
accepted compulsory ICJ jurisdiction
Gibraltar
the laws of the UK, where applicable, apply
Greece
based on codified Roman law; judiciary divided into civil,
criminal, and administrative courts; accepts compulsory ICJ
jurisdiction with reservations
Greenland
the laws of Denmark, where applicable, apply
Grenada
based on English common law; has not accepted compulsory ICJ
jurisdiction
Guam
modeled on US; US federal laws apply
Guatemala
civil law system; judicial review of legislative acts; has
not accepted compulsory ICJ jurisdiction
Guernsey
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;
accepts compulsory ICJ jurisdiction with reservations
Guinea-Bissau
based on French civil law; accepts compulsory ICJ
jurisdiction
Guyana
based on English common law with certain admixtures of
Roman-Dutch law; has not accepted compulsory ICJ jurisdiction
Haiti
based on Roman civil law system; accepts compulsory ICJ
jurisdiction
Heard Island and McDonald Islands
the laws of Australia, where
applicable, apply
Holy See (Vatican City)
based on Code of Canon Law and revisions to
it
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
Hong Kong
based on English common law
Hungary
based on the German-Austrian legal system; accepts
compulsory ICJ jurisdiction with reservations
Iceland
civil law system based on Danish law; has not accepted
compulsory ICJ jurisdiction
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
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
Iran
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; has not accepted compulsory ICJ
jurisdiction
Ireland
based on English common law substantially modified by
indigenous concepts; judicial review of legislative acts in Supreme
Court; has not accepted compulsory ICJ jurisdiction
Isle of Man
the laws of the UK, where applicable, apply and Manx
statutes
Israel
mixture of English common law, British Mandate regulations,
and, in personal matters, Jewish, Christian, and Muslim legal
systems; has not accepted compulsory ICJ jurisdiction
Italy
based on civil law system; appeals treated as new trials;
judicial review under certain conditions in Constitutional Court;
has not accepted compulsory ICJ jurisdiction
Jamaica
based on English common law; has not accepted compulsory ICJ
jurisdiction
Jan Mayen
the laws of Norway, where applicable, apply
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
Jersey
the laws of the UK, where applicable, apply and local
statutes; justice is administered by the Royal Court
Jordan
based on Islamic law and French codes; judicial review of
legislative acts in a specially provided High Tribunal; has not
accepted compulsory ICJ jurisdiction
Kazakhstan
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
Kiribati
English common law supplemented by local, customary law
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
Korea, South
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
Martti AHTISAARI's Plan for Kosovo's supervised independence
Kuwait
civil law system with Islamic law significant in personal
matters; has not accepted compulsory ICJ jurisdiction
Kyrgyzstan
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; has not accepted compulsory ICJ
jurisdiction
Latvia
based on civil law system with traces of Socialist legal
traditions and practices; has not accepted compulsory ICJ
jurisdiction
Lebanon
mixture of Ottoman law, canon law, Napoleonic code, and
civil law; no judicial review of legislative acts; 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
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
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
Liechtenstein
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; has not accepted compulsory
ICJ jurisdiction
Luxembourg
based on civil law system; accepts compulsory ICJ
jurisdiction
Macau
based on Portuguese civil law system
Macedonia
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
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
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
Maldives
based on Islamic law with admixtures of English common law
primarily in commercial matters; 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
Malta
based on English common law and Roman civil law; accepts
compulsory ICJ jurisdiction with reservations
Marshall Islands
based on adapted Trust Territory laws, acts of the
legislature, municipal, common, and customary laws; has not accepted
compulsory ICJ jurisdiction
Mauritania
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
Mayotte
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
Micronesia, Federated States of
based on adapted Trust Territory
laws, acts of the legislature, municipal, common, and customary
laws; has not accepted compulsory ICJ jurisdiction
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
Monaco
based on French law; has not accepted compulsory ICJ
jurisdiction
Mongolia
blend of Soviet and German systems that employ
"continental" or "civil" code; case-precedent may be used to inform
judges, but all decisions must refer to the law as written;
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
Montserrat
English common law and statutory law
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
Mozambique
based on Portuguese civil law system and customary law;
has not accepted compulsory ICJ jurisdiction
Namibia
based on Roman-Dutch law and 1990 constitution; has not
accepted compulsory ICJ jurisdiction
Nauru
acts of the Nauru Parliament and British common law; accepts
compulsory ICJ jurisdiction with reservations
Navassa Island
the laws of the US, where applicable, apply
Nepal
based on Hindu legal concepts and English common law; has not
accepted compulsory ICJ jurisdiction
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
Netherlands Antilles
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
New Zealand
based on English law, with special land legislation and
land courts for the Maori; accepts compulsory ICJ jurisdiction with
reservations
Nicaragua
civil law system; Supreme Court may review administrative
acts; accepts compulsory ICJ jurisdiction
Niger
based on French civil law system and customary law; has not
accepted compulsory ICJ jurisdiction
Nigeria
based on English common law, Islamic law (in 12 northern
states), and traditional law; accepts compulsory ICJ jurisdiction
with reservations
Niue
English common law; note - Niue is self-governing with the
power to make its laws
Norfolk Island
based on the laws of Australia, local ordinances and
acts; English common law applies in matters not covered by either
Australian or Norfolk Island law
Northern Mariana Islands
based on US system, except for customs,
wages, immigration laws, and taxation
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
Oman
based on English common law and Islamic law; ultimate appeal to
the monarch; has not accepted compulsory ICJ jurisdiction
Pakistan
based on English common law with provisions to accommodate
Pakistan's status as an Islamic state; accepts compulsory ICJ
jurisdiction with reservations
Palau
based on Trust Territory laws, acts of the legislature,
municipal, common, and customary laws; has not accepted compulsory
ICJ jurisdiction
Panama
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
Paraguay
based on Argentine codes, Roman law, and French codes;
judicial review of legislative acts in Supreme Court of Justice;
accepts compulsory ICJ jurisdiction
Peru
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
Pitcairn Islands
local island by-laws
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
Portugal
based on 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
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
Romania
based on civil law system; has not accepted compulsory ICJ
jurisdiction
Russia
based on civil law system; judicial review of legislative
acts; has not accepted compulsory ICJ jurisdiction
Rwanda
based on German and Belgian civil law systems and customary
law; judicial review of legislative acts in the Supreme Court; has
not accepted compulsory ICJ jurisdiction
Saint Barthelemy
the laws of France, where applicable, apply
Saint Helena
English common law and statutes supplemented by local
statutes
Saint Kitts and Nevis
based on English common law; has not accepted
compulsory ICJ jurisdiction
Saint Lucia
based on English common law; has not accepted compulsory
ICJ jurisdiction
Saint Martin
the laws of France, where applicable, apply
Saint Pierre and Miquelon
the laws of France, where applicable, apply
Saint Vincent and the Grenadines
based on English common law; has
not accepted compulsory ICJ jurisdiction
Samoa
based on English common law and local customs; judicial review
of legislative acts with respect to fundamental rights of the
citizen; has not accepted compulsory ICJ jurisdiction
San Marino
based on civil law system with Italian law influences;
has not accepted compulsory ICJ jurisdiction
Sao Tome and Principe
based on Portuguese legal system and customary
law; has not accepted compulsory ICJ jurisdiction
Saudi Arabia
based on Sharia 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
Serbia
based on civil law system
Seychelles
based on English common law, French civil law, and
customary law; has not accepted compulsory ICJ jurisdiction
Sierra Leone
based on English law and customary laws indigenous to
local tribes; has not accepted compulsory ICJ jurisdiction
Singapore
based on English common law; 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
Slovenia
based on civil law system; has not accepted compulsory ICJ
jurisdiction
Solomon Islands
English common law, which is widely disregarded; has
not accepted compulsory ICJ jurisdiction
Somalia
no national system; a mixture of English common law, Italian
law, Islamic Sharia, and Somali customary law; accepts compulsory
ICJ jurisdiction with reservations
South Africa
based on Roman-Dutch law and English common law; has
not accepted compulsory ICJ jurisdiction
South Georgia and South Sandwich Islands
the laws of the UK, where
applicable, apply; the senior magistrate from the Falkland Islands
presides over the Magistrates Court
Spain
civil law system, with regional applications; accepts
compulsory ICJ jurisdiction with reservations
Sri Lanka
a highly complex mixture of English common law,
Roman-Dutch, Kandyan, and Jaffna Tamil law; has not accepted
compulsory ICJ jurisdiction