List of national legal systems
The contemporary national legal systems 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. The science that studies law at the level of legal systems is called comparative law.
Both civil and common law systems can be considered the most widespread in the world: civil law because it is the most widespread by landmass and by population overall, and common law because it is employed by the greatest number of people compared to any single civil law system. The Napoleonic Code is one of the few documents that have influenced the whole world. More than two centuries after its promulgation, the Napoleonic Code is still living law in all of the world. Considered to be the first successful universal codification since Justinian, it has influenced the civil law systems of countries around the world. Even today the French Civil Code of 1804 has not been significantly changed and in many ways it is the most enduring legacy of the French Revolution.
Civil law
The 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 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*, North Macedonia, Montenegro, Slovenia, Serbia, Greece, Portugal and its former colonies, Turkey, and East Asian countries including Japan, South Korea and Taiwan ;
- 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.
- Napoleonic to Germanistic influence
- Germanistic to Napoleonic influence
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 |
 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 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 and traditional Armenian law. |
 Aruba | Based on Dutch civil law |
 Austria | Based on Germanic Civil law. The Allgemeines bürgerliches Gesetzbuch 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 |
 Benin | Based on Napoleonic Civil law. |
 Bolivia | Influenced by the Napoleonic Code |
 Bosnia and Herzegovina | Influenced by Austrian law. The Swiss civil law was a model for the Law on Obligations of 1978. |
 Brazil | Based on German, Italian, French and Portuguese law. However, in 2004 the Federal Constitution was amended to grant the Supreme Federal Court authority to issue binding precedents to settle controversies involving constitutional law - a mechanism that echoes the stare decisis principle typically found in common law systems. |
 Bulgaria | Civil Law system influenced by Germanic and Roman law systems |
 Burkina Faso | Based on French civil law system |
 Burundi | |
 Chad | Based on French civil law system |
 People's Republic of China | Based on Germanic Civil law with influences from the Soviet Socialist law 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 | Based on French civil law system |
 Cambodia | |
 Cape Verde | Based on Portuguese civil law |
 Central African Republic | Based on French civil law system |
 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 and Colombia 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, 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 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. |
 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" '. OGZ was in force from 1853 to 1946. After the World War II, 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" '. 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" 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, influenced by German and Soviet legal codes during occupation periods, substantially reformed to remove Soviet influence and elements of socialist law after the Velvet Revolution. The new Civil Code of the Czech Republic was introduced in 2014. |
 Denmark | Based on North Germanic law. Scandinavian-North Germanic civil law. |
 Dominican Republic | Based on 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 |
 Egypt | Based on Napoleonic civil law and Islamic law. |
 Equatorial Guinea | |
 Ethiopia | |
 Gabon | Based on French civil law system |
 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. 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 ; the Greek civil code replaced the Byzantine–Roman civil law in effect in Greece since its independence |
 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, 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 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 North Germanic law. Germanic traditional laws and influenced by Medieval Norwegian and Danish laws. |
 India | 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 ..." |
 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-North Germanic civil law, based on North Germanic 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 |
 Taiwan | Influenced by German Civil Code. Enacted in 1931. |
 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 |
 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. Present: The Swiss civil law was a model for the Law on Obligations of 1978. |
 Slovakia | Descended from the Civil Code of the Austrian Empire, influenced by German and Soviet legal codes during occupation periods, substantially reformed to remove Soviet influence and elements of socialist law after the Velvet Revolution. |
 Slovenia | A Civil Law system influenced mostly by Germanic and Austro-Hungarian law systems |
 South Korea | Based on German civil law system. Also largely influenced by Japanese civil law which itself modelled after German one. Korean Civil Code was introduced 1958 and fully enacted by 1960. |
 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. |
 Suriname | Based on Dutch civil law |
 Sweden | Scandinavian-North Germanic 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 assimilated very few elements of foreign laws whatsoever. 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 North Germanic 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 |
 Syria | Based on Napoleonic civil law. |
 Timor-Leste | Based on Portuguese civil law |
 Turkey | Modeled after the Swiss civil law of 1907. |
 Ukraine | Civil Code of Ukraine of 2004 |
 United States – Louisiana | Law in the state of Louisiana is based on French and Spanish civil law 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. |
 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
Common law and equity are systems of law whose sources are the decisions in cases by judges. In addition, 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. 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, Australia, New Zealand, Bangladesh, India, Pakistan, South Africa, Canada, Hong Kong, the United States, 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 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. |
 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, 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 | 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 arising from the period of the British Mandate, 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 | 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 |
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 is based on legal precedent and reasoning by analogy, 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.
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 and Fiqh 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, who used the methods of Ijma, Qiyas, Ijtihad and Urf to derive Fatwā. An Ulema was required to qualify for an Ijazah at a Madrasa 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
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 | Based on Roman & Italian civil law and Catholic canon law |