List of national legal systems - wikipedia List of national legal systems Legal systems of the world The contemporary legal systems of the world are generally based on one of four basic systems : civil law, common law, statutory law, religious law or combinations of these. However, the legal system of each country is shaped by its unique history and so incorporates individual variations. Both civil ( also known as Roman ) and common law systems can be considered the most widespread in the world : civil law because it is the most widespread by landmass, and common law because it is employed by the greatest number of people. Contents 1 Civil law 2 Common law 3 Religious law 4 Pluralistic systems 4.1 Civil law and canon law 4.2 Civil law and common law 4.3 Civil law and sharia law 4.4 Common law and sharia law 5 Hybrid law 6 Perceptions 7 By geography 8 See also 9 References 9.1 Sources 10 External links Civil law Main article : Civil law ( legal system ) Shamash ( the Babylonian sun god ) hands King Hammurabi a code of law The central source of law that is recognized as authoritative is codifications in a constitution or statute passed by legislature, to amend a code. While the concept of codification dates back to the Code of Hammurabi in Babylon ca. 1790 BC, civil law systems derive from the Roman Empire and, more particularly, the Corpus Juris Civilis issued by the Emperor Justinian ca. AD 529. This was an extensive reform of the law in the Byzantine Empire, bringing it together into codified documents. Civil law was also partly influenced by religious laws such as Canon law and Islamic law. Civil law today, in theory, is interpreted rather than developed or made by judges. Only legislative enactments ( rather than legal precedents, as in common law ) are considered legally binding. Scholars of comparative law and economists promoting the legal origins theory usually subdivide civil law into four distinct groups : French civil law : in France, the Benelux countries, Italy, Romania, Spain and former colonies of those countries ; German civil law : in Germany, Austria, Russia, Switzerland, Estonia, Latvia, Bosnia and Herzegovina, Croatia, Kosovo *, Macedonia, Montenegro, Slovenia, Serbia, Greece, Portugal and its former colonies, Turkey, and Japan ; Scandinavian civil law : in Denmark, Norway and Sweden. As historically integrated in the Scandinavian cultural sphere, Finland and Iceland also inherited the system. Chinese law : a mixture of civil law and socialist law in use in the People 's Republic of China. However, some of these legal systems are often and more correctly said to be of hybrid nature : Napoleonic to Germanistic influence ( Italian civil law ) The Italian civil code of 1942 replaced the original one of 1865, introducing germanistic elements due to the geopolitical alliances of the time. The Italian approach has been imitated by other countries including the Netherlands ( 1992 ), Argentina ( 2014 ), Brazil ( 2002 ) and Portugal ( 1966 ). Most of them have innovations introduced by the Italian legislation, including the unification of the civil and commercial codes. Germanistic to Napoleonic influence ( Swiss civil law ) The Swiss civil code is considered mainly influenced by the German civil code and partly influenced by the French civil code. The civil code of the Republic of Turkey is a slightly modified version of the Swiss code, adopted in 1926 during Mustafa Kemal Atatürk 's presidency as part of the government 's progressive reforms and secularization. A comprehensive list of countries that base their legal system on a codified civil law follows : Country Description Albania Based on Napoleonic Civil law. The Civil Code of the Republic of Albania, 1991 ( 1 ) Angola Based on Portuguese civil law Argentina The Spanish legal tradition had a great influence on the Civil Code of Argentina, basically a work of the Argentine jurist Dalmacio Vélez Sársfield, who dedicated five years of his life on this task. The Civil Code came into effect on 1 January 1871. Beyond the influence of the Spanish legal tradition, the Argentinian Civil Code was also inspired by the Draft of the Brazilian Civil Code, the Draft of the Spanish Civil Code of 1851, the Napoleonic code and the Chilean Civil Code. The sources of this Civil Code also include various theoretical legal works, mainly of the great French jurists of the 19th century. It was the first Civil Law that consciously adopted as its cornerstone the distinction between i. rights from obligations and ii. real property rights, thus distancing itself from the French model. The Argentinian Civil Code was also in effect in Paraguay, as per a Paraguayan law of 1880, until the new Civil Code went in force in 1987. In Argentina, this 1871 Civil Code remained in force until August 2015, when it was replaced by the new Código Civil y Comercial de la Nación. During the second half of the 20th century, the German legal theory became increasingly influential in Argentina. Andorra Courts apply the customary laws of Andorra, supplemented with Roman law and customary Catalan law. Armenia Based on Napoleonic Civil law. The Legal System of Armenia Aruba Based on Dutch civil law Austria Based on Germanic Civil law. The Allgemeines bürgerliches Gesetzbuch ( ABGB ) of 1811 Azerbaijan Based on German, French, Russian and traditional Azerbaijani Law Belarus Based on Germanic Civil law Belgium The Napoleonic Code is still in use, although it is heavily modified ( especially concerning family law ) Benin Based on Napoleonic Civil law. Bolivia Influenced by the Napoleonic Code Bosnia and Herzegovina Influenced by Austrian law. The Swiss civil law ( Zivilgesetzbuch ) was a model for the Law on Obligations of 1978. Brazil Based on the German, Italian, French and Portuguese doctrine and codes. Bulgaria Civil Law system influenced by Germanic and Roman law systems Burkina Faso Burundi Chad People 's Republic of China Based on Germanic Civil law with influences from the Soviet Socialist from Soviet Union Republic of the Congo Based on the Napoleonic Civil law. Democratic Republic of the Congo Based on Belgian civil law Cote d'Ivoire Cambodia Cape Verde Based on Portuguese civil law Central African Republic Chile Based on the Chilean Civil Law inspired by the Napoleonic Civil Law. The Spanish legal tradition exercised an especially great influence on the civil code of Chile. On its turn, the Chilean civil code influenced to a large degree the drafting of the civil codes of other Latin - American states. For instance, the codes of Ecuador ( 1861 ) and Colombia ( 1873 ) constituted faithful reproductions of the Chilean code, but for very few exceptions. The compiler of the Civil Code of Chile, Venezuelan Andrés Bello, worked for its completion for almost 30 years, using elements, of the Spanish law on the one hand, and of other Western laws, especially of the French one, on the other. Indeed, it is noted that he consulted and used all of the codes that had been issued till then, starting from the era of Justinian. The Civil Code came into effect on 1 January 1857. The influence of the Napoleonic code and the Law of Castile of the Spanish colonial period ( especially the Siete Partidas ), is great ; it is observed however that e.g. in many provisions of property or contract law, the solutions of the French code civil were put aside in favor of pure Roman law or Castilian law. Colombia Based on the Chilean Civil Law. Civil code introduced in 1873. Nearly faithful reproduction of the Chilean civil code Costa Rica Based on the Napoleonic Civil Law. First Civil Code ( a part of the General Code or Carrillo Code ) came into effect in 1841 ; its text was inspired by the South Peruvian Civil Code of Marshal Andres de Santa Cruz. The present Civil Code went into effect 1 January 1888, and was influenced by the Napoleonic Code and the Spanish Civil Code of 1889 ( from its 1851 draft version ). Croatia Based on the Germanic Civil Law. Croatian Law system is largely influenced by German and Austrian law systems. It is significantly influenced by the Civil Code of the Austrian Empire from 1811, known in Croatia as `` General Civil Law '' ( `` Opći građanski zakon '' ). OGZ was in force from 1853 to 1946. The Independent State of Croatia, a Nazi - controlled puppet state that was established in 1941 during World War II, used the OGZ as a basis for the 1943 `` Base of the Civil Code for the Independent State of Croatia '' ( `` Osnova građanskoga zakona za Nezavisnu Državu Hrvatsku '' ). After the War, Croatia become a member of the Yugoslav Federation which enacted in 1946 the `` Law on immediate voiding of regulations passed before April 6, 1941 and during the enemy occupation '' ( `` Zakon o nevaženju pravnih propisa donesenih prije 6. travnja 1941. i za vrijeme neprijateljske okupacije '' ). By this law OGZ was declared invalid as a whole, but implementation of some of its legal rules was approved. During the post-War era, the Croatian legal system become influenced by elements of the socialist law. Croatian civil law was pushed aside, and it took norms of public law and legal regulation of the social ownership. After Croatia declared independence from Yugoslavia on June 25, 1991, the previous legal system was used as a base for writing new laws. `` The Law on Obligations '' ( `` Zakon o obveznim odnosima '' ) was enacted in 2005. Today, Croatia as a European union member state implements elements of the EU acquis into its legal system. Cuba Influenced by Spanish and American law with large elements of Communist legal theory. Curaçao Based on Dutch Civil Law. Czech Republic Based on Germanic civil law. Descended from the Civil Code of the Austrian Empire ( 1811 ), influenced by German ( 1939 -- 45 ) and Soviet ( 1947 / 68 -- 89 ) legal codes during occupation periods, substantially reformed to remove Soviet influence and elements of socialist law after the Velvet Revolution ( 1989 ). The new Civil Code of the Czech Republic was introduced in 2014. Denmark Based on Nordic law. Scandinavian - German civil law Dominican Republic Based by the Napoleonic Code Ecuador Based on the Chilean civil law. Civil code introduced in 1861. El Salvador Estonia Based on German civil law. Finland Based on Nordic law. France Based on Napoleonic code ( code civil of 1804 ) Egypt Based on Napoleonic civil law and Islamic law. Equatorial Guinea Ethiopia Gabon Guinea Based on French civil law system, customary law, and decree Guinea - Bissau Based on Portuguese civil law Georgia Germany Based on Germanic civil law. The Bürgerliches Gesetzbuch of 1900 ( `` BGB '' ). The BGB is influenced both by Roman and German law traditions. Greece Based on Germanic civil law. The Greek civil code of 1946, highly influenced by traditional Roman law and the German civil code of 1900 ( Bürgerliches Gesetzbuch ) ; the Greek civil code replaced the Byzantine -- Roman civil law in effect in Greece since its independence ( Νομική Διάταξη της Ανατολικής Χέρσου Ελλάδος, Legal Provision of Eastern Mainland Greece, November 1821 : ' Οι Κοινωνικοί Νόμοι των Αειμνήστων Χριστιανών Αυτοκρατόρων της Ελλάδος μόνοι ισχύουσι κατά το παρόν εις την Ανατολικήν Χέρσον Ελλάδα ', ' The Social ( i.e. Civil ) Laws of the Dear Departed Christian Emperors of Greece ( referring to the Byzantine Emperors ) alone are in effect at present in Eastern Mainland Greece ' ) Guatemala Based on Napoleonic civil law. Guatemala has had three Civil Codes : the first one from 1877, a new one introduced in 1933, and the one currently in force, which was passed in 1963. This Civil Code has suffered some reforms throughout the years, as well as a few derogations relating to areas which have subsequently been regulated by newer laws, such as the Code of Commerce and the Law of the National Registry of Persons. In general, it follows the tradition of the Roman - French system of civil codification. Regarding the theory of ' sources of law ' in the Guatemalan legal system, the ' Ley del Organismo Judicial ' recognizes ' the law ' as the main legal source ( in the sense of legislative texts ), although it also establishes ' jurisprudence ' as a complementary source. Although jurisprudence technically refers to judicial decisions in general, in practice it tends to be confused and identified with the concept of ' legal doctrine ', which is a qualified series of identical resolutions in similar cases pronounced by higher courts ( the Constitutional Court acting as a ' Tribunal de Amparo ', and the Supreme Court acting as a ' Tribunal de Casación ' ) whose theses become binding for lower courts. Haiti Based on Napoleonic civil law. Honduras Hungary Based on Germanic, codified Roman law with elements from Napoleonic civil law. Iceland Based on Nordic law. Germanic traditional laws and influenced by Medieval Norwegian and Danish laws. India ( only Goa, Daman and Diu and Dadra and Nagar Haveli ) Based on Portuguese civil law Italy Based on Germanic civil law, with elements of the Napoleonic civil code ; civil code of 1942 replaced the original one of 1865 Japan Based on Germanic civil law. Japanese civil code of 1895. Latvia Based on Napoleonic and German civil law, as it was historically before the Soviet occupation. While general principles of law are prerequisites in making and interpreting the law, case law is also regularly applied to present legal arguments in courts and explain application of law in similar cases. Civil law largely modeled after Napoleonic code mixed with strong elements of German civil law. Criminal law retains Russian and German legal traditions, while criminal procedure law has been fully modeled after practice accepted in Western Europe. Civil law of Latvia enacted on 1937. Lebanon Based on Napoleonic civil law. Lithuania Modeled after Dutch civil law Luxembourg Based on Napoleonic civil law. Libya Based on Napoleonic civil law, with Ottoman, Italian, and Egyptian sources Macau Based on the Portuguese civil law ; also influenced by the law of the PRC Mauritius Mexico Based on Napoleonic civil law. `` The origins of Mexico 's legal system are both ancient and classical, based on the Roman and French legal systems, and the Mexican system shares more in common with other legal systems throughout the world ( especially those in Latin America and most of continental Europe )... '' Mongolia Based on Germanic civil law. Montenegro Based on Napoleonic and German civil law. First : the General Property Code for the Principality of Montenegro of 1888, written by Valtazar Bogišić. Present : the Law on Obligations of 2008. Mozambique Based on Portuguese civil law Netherlands Based on Napoleonic code with German law influence Nepal Based on Civil Code Norway Scandinavian - German civil law. King Magnus VI the Lawmender unified the regional laws into a single code of law for the whole kingdom in 1274. This was replaced by Christian V 's Norwegian Code of 1687. Panama Paraguay The Paraguayan Civil Code in force since 1987 is largely influenced by the Napoleonic Code and the Argentinian Code Peru Based on civil law system ; accepts compulsory International Court of Justice ICJ jurisdiction with despotic and corrupting reservations ; Poland The Polish Civil Code in force since 1965 Portugal Influenced by the Napoleonic Code and later by the German Civil Law Republic of China ( Taiwan ) Codification derived from German BGB. Romania Civil Code came into force in 2011. Based on the Civil Code of Quebec, but also influenced by the Napoleonic Code and other French - inspired codes ( such as those of Italy, Spain and Switzerland ) Russia Civil Law system descendant from Roman Law through Byzantine tradition. Heavily influenced by German and Dutch norms in 1700 -- 1800s. Socialist - style modification in 1900s, and Continental European Law influences since 1990s. Rwanda Mixture of Belgian civil law and English common law São Tomé e Príncipe Based on Portuguese civil law Serbia First : the Civil Code of Principality of Serbia of 1844, written by Jovan Hadžić, was influenced by the Austrian Civil Code ( Allgemeines bürgerliches Gesetzbuch ). Present : The Swiss civil law ( Zivilgesetzbuch ) was a model for the Law on Obligations of 1978. Slovakia Descended from the Civil Code of the Austrian Empire ( 1811 ), influenced by German ( 1939 -- 45 ) and Soviet ( 1947 / 68 -- 89 ) legal codes during occupation periods, substantially reformed to remove Soviet influence and elements of socialist law after the Velvet Revolution ( 1989 ). Slovenia A Civil Law system influenced mostly by Germanic and Austro - Hungarian law systems Spain Influenced by the Napoleonic Code, it also has some elements of Spain 's legal tradition, starting with the Siete Partidas, a major legislative achievement from the Middle Ages. That body of law remained more or less unchanged until the 19th century, when the first civil codes were drafted, merging both the Napoleonic style with the Castilian traditions. Sweden Scandinavian - German civil law. Like all Scandinavian legal systems, it is distinguished by its traditional character and for the fact that it did not adopt elements of Roman law. It is indeed worth mentioning that it assimilated very few elements of foreign laws whatsoever. It is also interesting that the Napoleonic Code had no influence in codification of law in Scandinavia. The historical basis of the law of Sweden, just as for all Nordic countries, is Old German law. Codification of the law started in Sweden during the 18th century, preceding the codifications of most other European countries. However, neither Sweden, nor any other Nordic state created a civil code of the kind of the Code Civil or the BGB. Switzerland The Swiss Civil Code of 1908 and 1912 ( obligations ; fifth book ) Timor - Leste Based on Portuguese civil law Turkey Modeled after the Swiss civil law ( Zivilgesetzbuch ) of 1907. Ukraine Civil Code of Ukraine of 2004 Uruguay Uzbekistan Represents an evolution of Soviet civil law. Overwhelmingly strong impact of the Communist legal theory is traceable. Vietnam Communist legal theory and French civil law Venezuela Civil law Common law Main article : Common law King John of England signs Magna Carta Common law and equity ( legal concept ) are systems of law whose sources are the decisions in cases by judges. Alongside, every system will have a legislature that passes new laws and statutes. The relationships between statutes and judicial decisions can be complex. In some jurisdictions, such statutes may overrule judicial decisions or codify the topic covered by several contradictory or ambiguous decisions. In some jurisdictions, judicial decisions may decide whether the jurisdiction 's constitution allowed a particular statute or statutory provision to be made or what meaning is contained within the statutory provisions. Statutes were allowed to be made by the government. Common law developed in England, influenced by Anglo - Saxon law and to a much lesser extent by the Norman conquest of England, which introduced legal concepts from Norman law, which, in turn, had its origins in Salic law. Common law was later inherited by the Commonwealth of Nations, and almost every former colony of the British Empire has adopted it ( Malta being an exception ). The doctrine of stare decisis, also known as case law or precedent by courts, is the major difference to codified civil law systems. Common law is currently in practice in Ireland, most of the United Kingdom ( England and Wales and Northern Ireland ), Australia, New Zealand, Bangladesh, India ( excluding Goa ), Pakistan, South Africa, Canada ( excluding Quebec ), Hong Kong, the United States ( on a state level excluding Louisiana ), and many other places. In addition to these countries, several others have adapted the common law system into a mixed system. For example, Nigeria operates largely on a common law system, but incorporates religious law. In the European Union, the Court of Justice takes an approach mixing civil law ( based on the treaties ) with an attachment to the importance of case law. One of the most fundamental documents to shape common law is the English Magna Carta, which placed limits on the power of the English Kings. It served as a kind of medieval bill of rights for the aristocracy and the judiciary who developed the law. Country Description American Samoa Based on law of the United States Antigua and Barbuda Based on English common law Australia Based on English common law. Some Indigenous Aboriginal laws are partially recognised in the system. Bahamas Based on English common law Bangladesh Based on English common law, with family law heavily based on Shar'iah law. Barbados Based on English common law Belize Based on English common law Bhutan Based on English common law, with Indian influence. Religious law influences personal law. British Virgin Islands Based on English common law Canada Based on English common law, except in Quebec, where a civil law system based on French law prevails in most matters of a civil nature, such as obligations ( contract and delict ), property law, family law and private matters. Federal statutes take into account the bijuridical nature of Canada and use both common law and civil law terms where appropriate. Cayman Islands Based on English common law Cyprus Based on English common law as inherited from British colonisation, with civil law influences, particularly in criminal law. Dominica Based on English common law England and Wales ( UK ) Primarily common law, with early Roman and some modern continental European influences Fiji Based on English common law Gibraltar Based on English common law Ghana Grenada Based on English common law Hong Kong Principally based on English common law India Based on English common law, except in Goa, Daman and Diu and Dadra and Nagar Haveli which follow a Civil law system based on the Portuguese Civil Law Ireland Based on Irish law before 1922, which was itself based on English common law Israel Based on English common law from the period of the British Mandate ( that includes laws from Ottoman Empire time ), also incorporating civil law and fragments of Halakha and Sharia for family law cases Jamaica Based on English common law Kiribati Based on English common law Liberia Based on Anglo - American and customary law Marshall Islands Based on law of the United States Myanmar Based on English common law Nauru Based on English common law Nepal Based on English common law New Zealand Based on English common law Northern Ireland ( UK ) Based on Irish law before 1921, in turn based on English common law Palau Based on law of the United States Pakistan Based on English common law with some provisions of Islamic law Saint Kitts and Nevis Based on English common law Saint Vincent and the Grenadines Based on English common law Singapore Based on English common law, but Muslims are subject to the Administration of Muslim Law Act, which gives the Sharia Court jurisdiction over Muslim personal law, e.g., marriage, inheritance and divorce. Tonga Based on English common law Trinidad and Tobago Based on English common law Tuvalu Based on English common law Uganda Based on English common law United States Federal courts and 49 states use the legal system based on English common law, which has diverged somewhat since the mid-nineteenth century in that they look to each other 's cases for guidance on issues of first impression and rarely, if ever, look at contemporary cases on the same issue in the UK or the Commonwealth. Law in the state of Louisiana is based on French and Spanish civil law ( see above ) Religious law Main article : Religious law Religious law refers to the notion of a religious system or document being used as a legal source, though the methodology used varies. For example, the use of Jewish and Halakha for public law has a static and unalterable quality, precluding amendment through legislative acts of government or development through judicial precedent ; Christian Canon law is more similar to civil law in its use of codes ; and Islamic Sharia law ( and Fiqh jurisprudence ) is based on legal precedent and reasoning by analogy ( Qiyas ), and is thus considered similar to common law. The main kinds of religious law are Sharia in Islam, Halakha in Judaism, and canon law in some Christian groups. In some cases these are intended purely as individual moral guidance, whereas in other cases they are intended and may be used as the basis for a country 's legal system. The latter was particularly common during the Middle Ages. Aleppo Codex : 10th century Hebrew Bible with Masoretic pointing The Halakha is followed by orthodox and conservative Jews in both ecclesiastical and civil relations. No country is fully governed by Halakha, but two Jewish people may decide, because of personal belief, to have a dispute heard by a Jewish court, and be bound by its rulings. The Islamic legal system of Sharia ( Islamic law ) and Fiqh ( Islamic jurisprudence ) is the most widely used religious law, and one of the three most common legal systems in the world alongside common law and civil law. It is based on both divine law, derived from the Qur'an and Sunnah, and the rulings of Ulema ( jurists ), who used the methods of Ijma ( consensus ), Qiyas ( analogical deduction ), Ijtihad ( research ) and Urf ( common practice ) to derive Fatwā ( legal opinions ). An Ulema was required to qualify for an Ijazah ( legal doctorate ) at a Madrasa ( law school / college ) before they could issue Fatwā. During the Islamic Golden Age, classical Islamic law may have had an influence on the development of common law and several civil law institutions. Sharia law governs a number of Islamic countries, including Saudi Arabia and Iran, though most countries use Sharia law only as a supplement to national law. It can relate to all aspects of civil law, including property rights, contracts or public law. Country Description Afghanistan Islamic law & American / British law after invasion Egypt Islamic law is ensured in Article 2 of the Egyptian constitution. The Gambia English common law, Islamic law and customary law Iran Shia Islamic law Libya Islamic law Mauritania mix of Islamic law and French Civil Codes, Islamic law largely applicable to family law. Morocco mix of Islamic law and French Civil Codes, Islamic law largely applicable to family law. Halakha recognized to family law cases for Jewish citizens. Nigeria Sharia in the northern states, common law in the south and at the federal level. Oman Sharia and tribal custom laws Saudi Arabia Islamic law Sudan Based on Islamic law Yemen Islamic law Pluralistic systems Civil law and canon law Main article : Canon law ( Catholic Church ) Canon law is not divine law, properly speaking, because it is not found in revelation. Instead, it is seen as human law inspired by the word of God and applying the demands of that revelation to the actual situation of the church. Canon law regulates the internal ordering of the Catholic Church, the Eastern Orthodox Church and the Anglican Communion. Canon law is amended and adapted by the legislative authority of the church, such as councils of bishops, individual bishops for their respective sees, the Pope for the entire Catholic Church, and the British Parliament for the Church of England. Country Description Vatican City / Holy See Based on Roman, Italian, and Catholic canon law Civil law and common law Country Description Botswana Based on South African law. An 1891 proclamation by the High Commissioner for Southern Africa applied the law of the Cape Colony ( now part of South Africa ) to the Bechuanaland Protectorate ( now Botswana ). Cameroon Cyprus Based on English common law ( Cyprus was a British colony 1878 -- 1960 ), with admixtures of French and Greek civil and public law, Italian civil law, Indian contract law, Greek Orthodox canon law, Muslim religious law, and Ottoman civil law. Guyana Jersey The Bailiwick of Jersey 's legal system draws on local legislation enacted by the States of Jersey, Norman customary law, English common law and modern French civil law Lesotho Based on South African law. An 1884 proclamation by the High Commissioner for Southern Africa applied the law of the Cape Colony ( now part of South Africa ) to Basutoland ( now Lesotho ). Louisiana ( U.S. ) Based on French and Spanish civil law, but federal laws ( based on common law ) are also in effect in Louisiana because of federal Supremacy Clause. Malta Initially based on Roman Law and eventually progressed to the Code de Rohan, the Napoleonic Code with influences from Italian Civil Law. English common law however is also a source of Maltese Law, most notably in Public Law Mauritius Laws governing the Mauritian penal system are derived partly from French civil law and British common law. Namibia Based on South African law. South Africa conquered South - West Africa ( now Namibia ) in 1915, and a 1919 proclamation by the Governor - General applied the law of the Cape Province of South Africa to the territory. Philippines Based on Spanish law ; influenced by U.S. common law after 1898 Spanish -- and Philippine -- American Wars, personal law based on sharia law applies to Muslims Puerto Rico ( U.S. ) Based on Spanish law ; influenced by U.S. common law after 1898 ( victory of the U.S. over Spain in the Spanish -- American War of 1898 and cession of Puerto Rico to the U.S. ) ; federal laws ( based on common law ) are in effect because of federal Supremacy Clause. Quebec ( Canada ) After the 1763 Treaty of Paris awarded French Canada to Great Britain, the British initially attempted to impose English Common Law, but in response to the deteriorating political situation in the nearby Thirteen Colonies, the Quebec Act was passed in 1774, which allowed a mix of English Common Law and customary civil law, based on the Coutume de Paris. Codification occurred in 1866 with the enactment of the Civil Code of Lower Canada, which continued in force when the modern Province of Quebec was created at Confederation in 1867. Canadian federal law in force in Quebec is based on common law, but federal statutes also take into account the bijuridical nature of Canada and use both common law and civil law terms where appropriate. Saint Lucia Scotland ( UK ) Based on Roman and continental law, with common law elements dating back to the High Middle Ages. Seychelles The substantive civil law is based on the French Civil Code. Otherwise the criminal law and court procedure are based on the English common law. See Seychelles Legal Environment. South Africa An amalgam of Roman - Dutch civil law and English common law, as well as Customary Law. Sri Lanka An amalgam of English common law, Roman - Dutch civil law and Customary Law Swaziland Based on South African law. A 1907 proclamation by the High Commissioner for Southern Africa applied the Roman - Dutch common law of the Transvaal Colony ( now part of South Africa ) to Swaziland. Thailand The Thai legal system became an amalgam of German, Swiss, French, English, Japanese, Italian, and Indian laws and practices. Even today, Islamic laws and practices exist in four southern provinces. Over the years, Thai law has naturally taken on its own Thai identity. Vanuatu Consists of a mixed system combining the legacy of English common law, French civil law and indigenous customary law. Zimbabwe Based on South African law. An 1891 proclamation by the High Commissioner for Southern Africa applied the law of the Cape Colony ( now part of South Africa ) to Southern Rhodesia ( now Zimbabwe ). Civil law and sharia law Country Description Afghanistan Algeria Bahrain Comoros Djibouti Egypt Family Law ( personal Statute ) for Muslims based on Islamic Jurisprudence, Separate Personal Statute for non Muslims, and all other branches of Law are based on French civil law system Eritrea Indonesia Based on civil law of Holland and adat ( cultural law of Indonesia ) Jordan Mainly based on French Civil Code and Ottoman Majalla, Islamic law applicable to family law Morocco Based on Islamic law and French and Spanish civil law system Oman Qatar Based on Islamic law and Egyptian civil law system ( after the French civil law system ) Syria Based on Islamic law and French civil law system United Arab Emirates Based on Islamic law and Egyptian civil law system ( after the French civil law system ) Common law and sharia law Country Description Bangladesh Common law, personal law based on sharia law applies to Muslims Brunei Gambia Malaysia Based on English common law, personal law based on sharia law applies to Muslims Nigeria Sharia is applied in some northern states Pakistan Based on English Common Law, some Islamic law applications in inheritance. Tribal Law in FATA United Arab Emirates Based on Common law system in the Dubai International Financial Center ( DIFC Courts ) and Abu Dhabi Global Market ( ADGM ) Courts ( after the English Common law system ) Hybrid law Country Description India The most prominent example of a hybrid legal system is the Indian legal system. India follows a mixture of civil, common law and customary or religious law. Separate personal law codes apply to Muslims, Christians, and Hindus. Decisions by the Supreme Court of India and High Courts are binding on the lower courts. Further, most of the laws are statutory and it also has a constitution which signifies the Civil nature of law in India. Ethiopia also follows this system. Perceptions Despite the usefulness of different classifications, every legal system has its own individual identity. Below are groups of legal systems, categorised by their geography. Click the `` show '' buttons on the right for the lists of countries. Some studies show that ethnic minorities are more likely to feel that the legal system within their particular jurisdiction is unfair and unjust. People with mental health issues, particularly young ones are also likely to have a low opinion of the justice system. By geography Law of Africa Sovereign states Algeria Angola Benin Botswana Burkina Faso Burundi Cameroon Cape Verde ( Cabo Verde ) Central African Republic Chad Comoros Democratic Republic of the Congo Republic of the Congo Djibouti Egypt Equatorial Guinea Eritrea Ethiopia Gabon The Gambia Ghana Guinea Guinea - Bissau Ivory Coast ( Côte d'Ivoire ) Kenya Lesotho Liberia Libya Madagascar Malawi Mali Mauritania Mauritius Morocco Mozambique Namibia Niger Nigeria Rwanda São Tomé and Príncipe Senegal Seychelles Sierra Leone Somalia South Africa South Sudan Sudan Swaziland Tanzania Togo Tunisia Uganda Zambia Zimbabwe States with limited recognition Sahrawi Arab Democratic Republic Somaliland Dependencies and other territories Canary Islands / Ceuta / Melilla ( Spain ) Madeira ( Portugal ) Mayotte / Réunion ( France ) Saint Helena / Ascension Island / Tristan da Cunha ( United Kingdom ) Law of North America Sovereign states Antigua and Barbuda Bahamas Barbados Belize Canada Costa Rica Cuba Dominica Dominican Republic El Salvador Grenada Guatemala Haiti Honduras Jamaica Mexico Nicaragua Panama Saint Kitts and Nevis Saint Lucia Saint Vincent and the Grenadines Trinidad and Tobago United States Dependencies and other territories Anguilla Aruba Bermuda Bonaire British Virgin Islands Cayman Islands Curaçao Greenland Guadeloupe Martinique Montserrat Puerto Rico Saint Barthélemy Saint Martin Saint Pierre and Miquelon Saba Sint Eustatius Sint Maarten Turks and Caicos Islands United States Virgin Islands Law of South America Sovereign states Argentina Bolivia Brazil Chile Colombia Ecuador Guyana Paraguay Peru Suriname Uruguay Venezuela Dependencies and other territories Falkland Islands French Guiana South Georgia and the South Sandwich Islands Law of Asia Sovereign states Afghanistan Armenia Azerbaijan Bahrain Bangladesh Bhutan Brunei Cambodia China Cyprus East Timor ( Timor - Leste ) Egypt Georgia India Indonesia Iran Iraq Israel Japan Jordan Kazakhstan North Korea South Korea Kuwait Kyrgyzstan Laos Lebanon Malaysia Maldives Mongolia Myanmar Nepal Oman Pakistan Philippines Qatar Russia Saudi Arabia Singapore Sri Lanka Syria Tajikistan Thailand Turkey Turkmenistan United Arab Emirates Uzbekistan Vietnam Yemen States with limited recognition Abkhazia Artsakh Northern Cyprus Palestine South Ossetia Taiwan Dependencies and other territories British Indian Ocean Territory Christmas Island Cocos ( Keeling ) Islands Hong Kong Macau Law in Europe Sovereign states Albania Andorra Armenia Austria Azerbaijan Belarus Belgium Bosnia and Herzegovina Bulgaria Croatia Cyprus Czech Republic Denmark Estonia Finland France Georgia Germany Greece Hungary Iceland Ireland Italy Kazakhstan Latvia Liechtenstein Lithuania Luxembourg Macedonia Malta Moldova Monaco Montenegro Netherlands Norway Poland Portugal Romania Russia San Marino Serbia Slovakia Slovenia Spain Sweden Switzerland Turkey Ukraine United Kingdom Vatican City States with limited recognition Abkhazia Artsakh Kosovo Northern Cyprus South Ossetia Transnistria Dependencies and other entities Åland Faroe Islands Gibraltar Guernsey Isle of Man Jersey Svalbard Other entities European Union Law of Oceania Sovereign states Australia Federated States of Micronesia Fiji Kiribati Marshall Islands Nauru New Zealand Palau Papua New Guinea Samoa Solomon Islands Tonga Tuvalu Vanuatu Associated states of New Zealand Cook Islands Niue Dependencies and other territories American Samoa Christmas Island Cocos ( Keeling ) Islands Easter Island French Polynesia Guam Hawaii New Caledonia Norfolk Island Northern Mariana Islands Pitcairn Islands Tokelau Wallis and Futuna See also Anarchist law Comparative law English common law International customary law Islamic law Legal pluralism Journal of Legal Pluralism Rule of law Rule According to Higher Law Socialist law Soviet law Tribal sovereignty Western law Comparative law wiki Legal education References Jump up ^ `` Legal Systems of the World '' ( PDF ). Jump up ^ Wood, Phillip ( 2007 ). Principles of International Insolvency. Sweet & Maxwell. Retrieved 30 August 2015. Jump up ^ Wood, Phillip ( 2008 ). Maps of World Financial Law : Law and practice of international finance series. Sweet & Maxwell. Retrieved 30 August 2015. Jump up ^ `` English Common Law is the most widespread legal system in the world '' ( PDF ). Sweet & Maxwell. November 2008. Retrieved 30 August 2015. Jump up ^ Badr, Gamal Moursi ( Spring 1978 ), `` Islamic Law : Its Relation to Other Legal Systems '', The American Journal of Comparative Law, 26 ( 2 ( Proceedings of an International Conference on Comparative Law, Salt Lake City, Utah, February 24 -- 25, 1977 ) ) : 187 -- 198 ( 196 -- 8 ), doi : 10.2307 / 839667 ^ Jump up to : Makdisi, John A. ( June 1999 ), `` The Islamic Origins of the Common Law '', North Carolina Law Review, 77 ( 5 ) : 1635 -- 1739 Jump up ^ Towards a Civil Code : The Italian Experience Jump up ^ On the Legal Method of the Uniform Commercial Code Jump up ^ `` Ministerio de Economía y Finanzas Públicas - Argentina ''. InfoLEG. Retrieved 2017 - 01 - 19. Jump up ^ `` Comienza a regir el nuevo Código Civil y Comercial ''. Jornadaonline.com. Retrieved 2017 - 01 - 19. Jump up ^ Andorra ( 11 / 07 ) Jump up ^ `` Opći građanski zakonik Hrvatska enciklopedija ''. Enciklopedija.hr. Retrieved 2017 - 01 - 19. Jump up ^ Croatian legal history in the European context, Dalibor Čepulo, p. 357 ^ Jump up to : The World Factbook Jump up ^ Jaime B. Berger Stender Attorney at Law author, Tijuana, B.C., Mexico Jump up ^ Valeriu Stoica ( 2009 ). Drept civil. Drepturile reale principale. Bucharest : C.H. Beck. pp. XIII. Jump up ^ `` Magna Carta ''. Retrieved 10 November 2006. Jump up ^ Nandini Chavan, Qutub Jehan Kidwai, Personal Law Reforms and Gender Empowerment : A Debate on Uniform Civil Code, Page 245, Hope India Publications, 2006 Jump up ^ `` Archived copy '' ( PDF ). Archived from the original ( PDF ) on 23 February 2015. Retrieved 2015 - 01 - 30. Jump up ^ The World Factbook Jump up ^ El - Gamal, Mahmoud A. ( 2006 ), Islamic Finance : Law, Economics, and Practice, Cambridge University Press, p. 16, ISBN 0 - 521 - 86414 - 3 Jump up ^ Badr, Gamal Moursi ( Spring 1978 ), `` Islamic Law : Its Relation to Other Legal Systems '', The American Journal of Comparative Law, 26 ( 2 -- Proceedings of an International Conference on Comparative Law, Salt Lake City, Utah, 24 -- 25 February 1977 ) : 187 -- 198, doi : 10.2307 / 839667 Jump up ^ Makdisi, George ( April -- June 1989 ), `` Scholasticism and Humanism in Classical Islam and the Christian West '', Journal of the American Oriental Society, 109 ( 2 ) : 175 -- 182 ( 175 -- 77 ), doi : 10.2307 / 604423 Jump up ^ Badr, Gamal Moursi ( Spring 1978 ), `` Islamic Law : Its Relation to Other Legal Systems '', The American Journal of Comparative Law, 26 ( 2 -- Proceedings of an International Conference on Comparative Law, Salt Lake City, Utah, 24 -- 25 February 1977 ) : 187 -- 198 ( 196 -- 8 ), doi : 10.2307 / 839667 ^ Jump up to : Pain, JH ( July 1978 ). `` The reception of English and Roman - Dutch law in Africa with reference to Botswana, Lesotho and Swaziland ''. The Comparative and International Law Journal of Southern Africa. 11 ( 2 ) : 137 -- 167. access - date = requires url = ( help ) Jump up ^ `` Mauritius - Penal System ''. Retrieved 19 March 2018. Jump up ^ Geraldo, Geraldine Mwanza ; Nowases, Isabella ( April 2010 ). `` Researching Namibian Law and the Namibian Legal System ''. Retrieved 7 May 2013. Jump up ^ This definition is partly disputed -- Thomson, Stephen, Mixed Jurisdiction and the Scottish Legal Tradition : Reconsidering the Concept of Mixture ( 2014 ) 7 ( 1 ) Journal of Civil Law Studies 51 - 91 Jump up ^ `` Types of courts in Dubai ''. Dubai.ae. Retrieved 2017 - 01 - 19. Jump up ^ Anticipatory injustice among adolescents, 2008 JL Woolard, 2008 Jump up ^ 12.30 EST ( 2015 - 02 - 05 ). `` Youth justice system is ' failing vulnerable young offenders ' Society ''. The Guardian. Retrieved 2017 - 01 - 19. Sources Moustaira Elina N., Comparative Law : University Courses ( in Greek ), Ant. N. Sakkoulas Publishers, Athens, 2004, ISBN 960 - 15 - 1267 - 5 Moustaira Elina N., Milestones in the Course of Comparative Law : Thesis and Antithesis ( in Greek ), Ant. N. Sakkoulas Publishers, Athens, 2003, ISBN 960 - 15 - 1097 - 4 External links World Legal Systems, Website of the Faculty of Law of the University of Ottawa Australian Institute of Comparative Legal Systems Factbook list of legal systems International & Foreign Law Community Law Core subjects Administrative law Constitutional law Contract Criminal law Deed Equity Evidence International law Law of obligations Procedure Civil Criminal Property law Public law Restitution Statutory law Tort Other subjects Agricultural law Aviation law Banking law Bankruptcy Commercial law Competition law Conflict of laws Construction law Consumer protection Corporate law Cyberlaw Election law Energy law Entertainment law Environmental law Family law Financial regulation Health law Immigration law Intellectual property International criminal law International human rights International slavery laws Labour Law of war Legal archaeology Legal fiction Maritime law Media law Military law Probate Estate Will and testament Product liability Public international law Space law Sports law Tax law Transport law Trust law Women in law Sources of law Charter Constitution Custom Divine right Human rights Natural and legal rights Case law Precedent Law making Ballot measure Codification Decree Edict Executive order Proclamation Legislation Delegated legislation Regulation Rulemaking Promulgation Repeal Treaty Statutory law Statute Act of Parliament Act of Congress ( US ) Legal systems Civil law Common law Chinese law Legal pluralism Religious law Canon law Hindu law Jain law Jewish law Sharia Roman law Socialist law Statutory law Xeer Yassa Legal theory Critical legal studies Comparative law Feminist Law and economics Legal formalism History Natural law International legal theory Principle of legality Rule of law Sociology Jurisprudence Adjudication Administration of justice Criminal justice Court - martial Dispute resolution Fiqh Lawsuit / Litigation Legal opinion Legal remedy Judge Justice of the peace Magistrate Judgment Judicial review Jurisdiction Jury Justice Practice of law Attorney Barrister Counsel Lawyer Legal representation Prosecutor Solicitor Question of fact Question of law Trial Trial advocacy Trier of fact Verdict Legal institutions Bureaucracy The bar The bench Civil society Court Election commission Executive Judiciary Law enforcement Legal education Law school Legislature Military Police Political party Tribunal Category Index Outline Portal Systems science Systems types Anatomical Art Biological Complex Complex adaptive Conceptual Coupled human -- environment Database Dynamical Ecological Economic Energy Formal Holarchic Information Legal Measurement Metric Multi-agent Nervous Nonlinear Operating Physical Planetary Political Sensory Social Star Writing Theoretical fields Chaos theory Complex systems Control theory Cybernetics Earth system science Living systems Sociotechnical system Systemics Urban metabolism World - systems theory analysis biology dynamics ecology engineering neuroscience pharmacology psychology theory thinking Systems scientists Alexander Bogdanov Russell L. Ackoff William Ross Ashby Ruzena Bajcsy Béla H. Bánáthy Gregory Bateson Anthony Stafford Beer Richard E. Bellman Ludwig von Bertalanffy Margaret Boden Kenneth E. Boulding Murray Bowen Kathleen Carley Mary Cartwright C. West Churchman Manfred Clynes George Dantzig Edsger W. Dijkstra Heinz von Foerster Stephanie Forrest Jay Wright Forrester Barbara Grosz Charles AS Hall Lydia Kavraki James J. Kay Faina M. Kirillova George Klir Allenna Leonard Edward Norton Lorenz Niklas Luhmann Humberto Maturana Margaret Mead Donella Meadows Mihajlo D. Mesarovic James Grier Miller Radhika Nagpal Howard T. Odum Talcott Parsons Ilya Prigogine Qian Xuesen Anatol Rapoport Peter Senge Claude Shannon Katia Sycara Francisco Varela Manuela M. Veloso Kevin Warwick Norbert Wiener Jennifer Wilby Anthony Wilden Applications Systems theory in anthropology Systems theory in archaeology Systems theory in political science Organizations List Principia Cybernetica Category Portal Commons Jurisprudence Legal theory Critical legal studies Comparative law Economic analysis International legal theory Legal history Philosophy of law Sociology of law Philosophers Alexy Allan Aquinas Aristotle Austin Beccaria Bentham Betti Bickel Blackstone Bobbio Bork Brożek Cardozo Castanheira Neves Chafee Coleman Del Vecchio Durkheim Dworkin Ehrlich Feinberg Fineman Finnis Frank Fuller Gardner George Green Grisez Grotius Gurvitch Habermas Han Hart Hegel Hobbes Hohfeld Hägerström Jellinek Jhering Kant Kelsen Köchler Kramer Llewellyn Lombardía Luhmann Lundstedt Lyons MacCormick Marx Nussbaum Olivecrona Pashukanis Perelman Petrazycki Pontes de Miranda Posner Pound Puchta Radbruch Rawls Raz Reale Reinach Renner Ross Rumi Savigny Scaevola Schmitt Shang Simmonds Somló Suárez Tribe Unger Voegelin Waldron Walzer Weber Theories Analytical jurisprudence Deontological ethics Interpretivism Legalism Legal moralism Legal positivism Legal realism Libertarian theories of law Natural law Paternalism Utilitarianism Virtue jurisprudence Concepts Dharma Fa Judicial interpretation Justice Legal system Li Rational - legal authority Related articles Law Political philosophy more... Category Law portal Philosophy portal WikiProject Law WikiProject Philosophy changes Lists of countries by laws and law enforcement rankings Age of Consent Legal candidacy for political office Criminal responsibility Legal drinking Legal driving Majority Legal marriage Retirement age Mandatory retirement School - leaving age Legal smoking Voting Suffrage Youth suffrage Working age Drugs Alcohol Alcohol consumption Alcohol law Bath salts Legal status of Mephedrone Legal status of MPDV Legal status of Methylone Cannabis Legality annual use lifetime use Cocaine use Legality Methamphetamine Legality LSD Legality Opiate use Salvia divinorum Legality Death Legality of euthanasia Homicide by decade Law enforcement killings Legality of suicide Legality of assisted suicide Guns Deaths Ownership Punishment Corporal punishment At home At school In court Death penalty Incarceration Obscenity Incest Laws Pornography Child pornography Simulated child pornography Drawn pornography depicting minors Internet pornography Prostitution Sexual assault Child sexual abuse Rape Sodomy law Sex trafficking Zoophilia Censorship Censorship by country Book censorship by country Film censorship by country Internet censorship by country Cartographic censorship Political censorship Video gaming censorship by country Human rights Children 's rights Children in the military Intersex rights LGBT Rights Slavery Human trafficking Freedom of movement by country In the air Abode Property and Environmental Air Estate Land Minerals Mining Mortgage Water Riparian water Business Corporate Corporate liability Competition Mergers and acquisitions Monopoly Legality of bitcoin by country or territory International ownership International waters Sea law Maritime law Antarctic Treaty System Other Abortion law Minors and abortion Animal rights Immigration law Human cloning National legal systems Police brutality Prisoner abuse Religious law Separation of church and state Sharia Size of police forces World Justice Project List of international rankings List of top international rankings by country Lists by country Social sciences Primary Anthropology archaeology cultural linguistics social Economics microeconomics macroeconomics Geography human integrative History cultural economic military political social Law jurisprudence legal history legal systems Political science international relations psephology public administration public policy Psychology abnormal biological cognitive developmental personality social Sociology criminology demography internet rural urban Interdisciplinary Anthrozoology Area studies Business studies Cognitive science Communication studies Community studies Cultural studies Development studies Education Environmental ( social science studies ) Food studies Gender studies Global studies History of technology Human ecology Information science International studies Media studies Philosophy of science economics history psychology social science Planning land use regional urban Political ecology Political economy Public health Regional science Science and technology studies Science studies historical Social work Other categorizations Humanities Geisteswissenschaft Human science Index Journals Outline Wikiversity Retrieved from `` https://en.wikipedia.org/w/index.php?title=List_of_national_legal_systems&oldid=837915550 '' Categories : Comparative law Law by country Legal systems Customary legal systems Hidden categories : Pages using citations with accessdate and no URL Use dmy dates from September 2011 All articles with unsourced statements Articles with unsourced statements from June 2014 Articles with unsourced statements from July 2013 Pages using div col with deprecated parameters Talk Contents About Wikipedia Български Bosanski Català Čeština Dansk Deutsch Eesti Español Français Galego 한국어 Hrvatski Bahasa Indonesia ქართული Lietuvių Magyar Bahasa Melayu Nederlands 日本 語 Norsk Polski Português Русский Slovenčina Српски / srpski Srpskohrvatski / српскохрватски Suomi Svenska தமிழ் ไทย Türkçe Українська Tiếng Việt 粵語 中文 26 more Edit links This page was last edited on 23 April 2018, at 20 : 06. Text is available under the Creative Commons Attribution - ShareAlike License ; additional terms may apply. By using this site, you agree to the Terms of Use and Privacy Policy. Wikipedia ® is a registered trademark of the Wikimedia Foundation, Inc., a non-profit organization. About Wikipedia

Question: is the usa common law or civil law
Answer: Common law