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The four major legal systems of the world today consist of civil law, common law, customary law, and religious law. However, each country often develops variations on each system or incorporates many other features into the system.

Civil law


Civil law is the most wide-spead system of law in the world. Countries that base their legal system on a codified civil law include:

Country Description
Albania
Austria
Belgium
Bulgaria
Brazil
Chile
China based on civil law system; derived from Soviet and continental civil code legal principles.
Columbia
Croatia
Czech Republic
Denmark
Dominican Republic
Ecuador
Estonia
Finland
France
Germany
Greece based on codified Roman law
Guatemala
Haiti
Hungary
Italy based on codified Roman law, with elements of the Napoleonic civil code.
Japan modeled after European civil law system with English-American influence.
Latvia Largely influenced by Germany, medium influences from Russian and Soviet law.
Luxembourg
Macau Based on the Portuguese strand of the continental tradition, itself much influenced by Germany; also influenced by the law of the PRC
Mexico
Netherlands
Norway
Panama
Peru
Poland
Portugal
Russia
Slovakia
Spain
Sweden
Switzerland
Thailand
Vietnam Communist legal theory and French civil law

Common law


Country Description
Australia based on English common law.
Canada based on English common law, except in Quebec, where civil law system based on French law prevails.
Hong Kong based on English common law
India based on English common law, separate personal law codes apply to Muslims, Christians, and Hindus.
Irish Republic based on English common law
New Zealand based on English common law
Pakistan based on English Common Law, some Islamic Law applications in inheritance. Tribal Law in FATA.
Singapore based on English common law.
United Kingdom common law tradition with early Roman and modern continental influences. English law (also includes Wales) and Northern Irish law is primarily common law; Scotland has its own unique system, generally regarded as mixed.
United States federal court system based on English common law; each state has its own unique legal system, of which all but one (Louisiana's) is based on English common law.

Customary law


Mongolia, Sri Lanka

Religious law


Saudi Arabia, Iran, Sudan, Syria, Vatican.

Mixed (or Pluralistic) Systems


Common law and civil law

Country Description
Argentina
Quebec (Canada)
Louisiana (US)
Scotland (United Kingdom)
South Africa

Civil law and customary law

External links


Law

Rechtssystem_(Recht) | Système juridique | 法系

 

This article is licensed under the GNU Free Documentation License. It uses material from the "Legal systems of the world".

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