Legal systems of the world

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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.

Contents

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
People's Republic of China based on civil law system; derived from Soviet and continental civil code legal principles.
Colombia
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
Malta Initially based on Roman Law and eventually progressed to the Code de Rohan, Code Napoleon with influences from Italian Civil Law. British Common Law however is also a source of Maltese Law, namely in Public Law
Mexico
Netherlands
Norway
Panama
Peru
Poland
Portugal
Russia
Slovakia
Spain
Sweden
Switzerland
Thailand
Vietnam Communist legal theory and French civil law

Common law

Main article: 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.
Republic of Ireland 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 English law (also includes Wales) and Northern Irish law is primarily common law, with early Roman and some modern continental influences. Scotland has its own unique system, Scots law, based on civil law, and 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

Main article: Customary law

Religious law

Main article: Religious law

Mixed (or Pluralistic) Systems

Civil law and common law

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

Civil law and customary law

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See also

External links

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Template:Gov-stub Template:Socio-stub[[fr:Syst�me juridique]]

References

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