Country
|
Legal system
|
Afghanistan
|
according to the new constitution, no law should be "contrary to Islam"; the state is obliged to create a prosperous and progressive society based on social justice, protection of human dignity, protection of human rights, realization of democracy, and to ensure national unity and equality among all ethnic groups and tribes; the state shall abide by the UN charter, international treaties, international conventions that Afghanistan signed, and the Universal Declaration of Human Rights
|
Akrotiri
|
the laws of the UK, where applicable, apply
|
Albania
|
has a civil law system; has not accepted compulsory ICJ jurisdiction; has accepted jurisdiction of the International Criminal Court for its citizens
|
Algeria
|
socialist, based on French and Islamic law; judicial review of legislative acts in ad hoc Constitutional Council composed of various public officials, including several Supreme Court justices; has not accepted compulsory ICJ jurisdiction
|
American Samoa
|
NA
|
Andorra
|
based on French and Spanish civil codes; no judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
|
Angola
|
based on Portuguese civil law system and customary law; recently modified to accommodate political pluralism and increased use of free markets
|
Anguilla
|
based on English common law
|
Antarctica
|
Antarctica is administered through meetings of the consultative member nations; decisions from these meetings are carried out by these member nations (with respect to their own nationals and operations) in accordance with their own national laws; US law, including certain criminal offenses by or against US nationals, such as murder, may apply extra-territorially; some US laws directly apply to Antarctica; for example, the Antarctic Conservation Act, 16 U.S.C. section 2401 et seq., provides civil and criminal penalties for the following activities, unless authorized by regulation of statute: the taking of native mammals or birds; the introduction of nonindigenous plants and animals; entry into specially protected areas; the discharge or disposal of pollutants; and the importation into the US of certain items from Antarctica; violation of the Antarctic Conservation Act carries penalties of up to $10,000 in fines and one year in prison; the National Science Foundation and Department of Justice share enforcement responsibilities; Public Law 95-541, the US Antarctic Conservation Act of 1978, as amended in 1996, requires expeditions from the US to Antarctica to notify, in advance, the Office of Oceans, Room 5805, Department of State, Washington, DC 20520, which reports such plans to other nations as required by the Antarctic Treaty; for more information, contact Permit Office, Office of Polar Programs, National Science Foundation, Arlington, Virginia 22230; telephone: (703) 292-8030, or visit their website at www.nsf.gov
|
Antigua and Barbuda
|
based on English common law
|
Argentina
|
mixture of US and West European legal systems; has not accepted compulsory ICJ jurisdiction
|
Armenia
|
based on civil law system
|
Aruba
|
based on Dutch civil law system, with some English common law influence
|
Ashmore and Cartier Islands
|
the laws of the Commonwealth of Australia and the laws of the Northern Territory of Australia, where applicable, apply
|
Australia
|
based on English common law; accepts compulsory ICJ jurisdiction, with reservations
|
Austria
|
civil law system with Roman law origin; judicial review of legislative acts by the Constitutional Court; separate administrative and civil/penal supreme courts; accepts compulsory ICJ jurisdiction
|
Azerbaijan
|
based on civil law system
|
Bahamas, The
|
based on English common law
|
Bahrain
|
based on Islamic law and English common law
|
Baker Island
|
the laws of the US, where applicable, apply
|
Bangladesh
|
based on English common law
|
Barbados
|
English common law; no judicial review of legislative acts
|
Bassas da India
|
the laws of France, where applicable, apply
|
Belarus
|
based on civil law system
|
Belgium
|
civil law system influenced by English constitutional theory; judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations
|
Belize
|
English law
|
Benin
|
based on French civil law and customary law; has not accepted compulsory ICJ jurisdiction
|
Bermuda
|
English law
|
Bhutan
|
based on Indian law and English common law; has not accepted compulsory ICJ jurisdiction
|
Bolivia
|
based on Spanish law and Napoleonic Code; has not accepted compulsory ICJ jurisdiction
|
Bosnia and Herzegovina
|
based on civil law system
|
Botswana
|
based on Roman-Dutch law and local customary law; judicial review limited to matters of interpretation; has not accepted compulsory ICJ jurisdiction
|
Bouvet Island
|
the laws of Norway, where applicable, apply
|
Brazil
|
based on Roman codes; has not accepted compulsory ICJ jurisdiction
|
British Indian Ocean Territory
|
the laws of the UK, where applicable, apply
|
British Virgin Islands
|
English law
|
Brunei
|
based on English common law; for Muslims, Islamic Shari'a law supersedes civil law in a number of areas
|
Bulgaria
|
civil law and criminal law based on Roman law; accepts compulsory ICJ jurisdiction
|
Burkina Faso
|
based on French civil law system and customary law
|
Burma
|
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 in recent years
|
Cameroon
|
based on French civil law system, with common law influence; has not accepted 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
|
derived from the legal system of Portugal
|
Cayman Islands
|
British common law and local statutes
|
Central African Republic
|
based on French law
|
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: Chile is in the process of completely overhauling its criminal justice system; a new, US-style adversarial system is being gradually implemented throughout the country with the final stage of implementation in the Santiago metropolitan region expected in June 2005
|
China
|
a complex amalgam of custom and statute, largely criminal law; rudimentary civil code in effect since 1 January 1987; new legal codes in effect since 1 January 1980; continuing efforts are being made to improve civil, administrative, criminal, and commercial law
|
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 in 1992-93; judicial review of executive and legislative acts; accepts compulsory ICJ jurisdiction, with reservations
|
Comoros
|
French and Sharia (Islamic) law in a new consolidated code
|
Congo, Democratic Republic of the
|
based on Belgian civil law system and tribal law; has not accepted compulsory ICJ jurisdiction
|
Congo, Republic of the
|
based on French civil law system and customary law
|
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; has not accepted compulsory ICJ jurisdiction
|
Croatia
|
based on civil law system
|
Cuba
|
based on Spanish and American law, with large elements of Communist legal theory; has not accepted compulsory ICJ jurisdiction
|
Cyprus
|
based on common law, with civil law modifications
|
Czech Republic
|
civil law system based on Austro-Hungarian codes; has not accepted compulsory ICJ jurisdiction; 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 laws of the UK, where applicable, apply
|
Djibouti
|
based on French civil law system, traditional practices, and Islamic law
|
Dominica
|
based on English common law
|
Dominican Republic
|
based on French civil codes; undergoing modification in 2004 towards an accusatory system
|
East Timor
|
UN-drafted legal system based on Indonesian law remains in place but will be replaced by civil and penal codes based on Portuguese law (2004)
|
Ecuador
|
based on civil law system; has not accepted compulsory ICJ jurisdiction
|
Egypt
|
based on English common law, Islamic law, and 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; accepts compulsory ICJ jurisdiction, with reservations
|
Equatorial Guinea
|
partly based on Spanish civil law and tribal custom
|
Eritrea
|
primary basis is the Ethiopian legal code of 1957, with revisions; new civil, commercial, and penal codes have not yet been promulgated; also relies on customary and post-independence-enacted laws and, for civil cases involving Muslims, Sharia law
|
Estonia
|
based on civil law system; no judicial review of legislative acts
|
Ethiopia
|
currently transitional mix of national and regional courts
|
Europa Island
|
the laws of France, where applicable, apply
|
Falkland Islands (Islas Malvinas)
|
English common law
|
Faroe Islands
|
Danish
|
Fiji
|
based on British system
|
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
|
French Guiana
|
French legal system
|
French Polynesia
|
based on French system
|
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, Koranic law, and customary law; accepts compulsory ICJ jurisdiction, with reservations
|
Georgia
|
based on civil law system
|
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
|
English law
|
Glorioso Islands
|
the laws of France, where applicable, apply
|
Greece
|
based on codified Roman law; judiciary divided into civil, criminal, and administrative courts
|
Greenland
|
Danish
|
Grenada
|
based on English common law
|
Guadeloupe
|
French legal system
|
Guam
|
modeled on US; US federal laws apply
|
Guatemala
|
civil law system; judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
|
Guernsey
|
English law and local statute; justice is administered by the Royal Court
|
Guinea
|
based on French civil law system, customary law, and decree; legal codes currently being revised; has not accepted compulsory ICJ jurisdiction
|
Guinea-Bissau
|
NA
|
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
|
Howland Island
|
the laws of the US, where applicable, apply
|
Hungary
|
rule of law based on Western model
|
Iceland
|
civil law system based on Danish law; has not accepted compulsory ICJ jurisdiction
|
India
|
based on English common law; limited judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations
|
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
|
the Constitution codifies Islamic principles of government
|
Iraq
|
based on civil and Islamic law under the Iraqi Interim Government (IG) and Transitional Administrative Law (TAL)
|
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
|
Israel
|
mixture of English common law, British Mandate regulations, and, in personal matters, Jewish, Christian, and Muslim legal systems; in December 1985, Israel informed the UN Secretariat that it would no longer accept 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 European civil law system with English-American influence; judicial review of legislative acts in the Supreme Court; accepts compulsory ICJ jurisdiction with reservations
|
Jarvis Island
|
the laws of the US, where applicable, apply
|
Jersey
|
English law and local statute; justice is administered by the Royal Court
|
Johnston Atoll
|
the laws of the US, where applicable, apply
|
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
|
Juan de Nova Island
|
the laws of France, where applicable, apply
|
Kazakhstan
|
based on civil law system
|
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
|
Kingman Reef
|
the laws of the US, where applicable, apply
|
Kiribati
|
NA
|
Korea, North
|
based on German 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
|
Kuwait
|
civil law system with Islamic law significant in personal matters; has not accepted compulsory ICJ jurisdiction
|
Kyrgyzstan
|
based on civil law system
|
Laos
|
based on traditional customs, French legal norms and procedures, and socialist practice
|
Latvia
|
based on civil law system
|
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; has not accepted compulsory ICJ jurisdiction
|
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
|
Libya
|
based on Italian civil law system 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; accepts compulsory ICJ jurisdiction, with reservations
|
Lithuania
|
based on civil law system; legislative acts can be appealed to the constitutional court
|
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
|
Madagascar
|
based on French civil law system and traditional Malagasy law; has not accepted compulsory ICJ jurisdiction
|
Malawi
|
based on English common law and customary law; judicial review of legislative acts in the Supreme Court of Appeal; has not accepted compulsory ICJ jurisdiction
|
Malaysia
|
based on English common law; judicial review of legislative acts in the Supreme Court at request of supreme head of the federation; 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 (which was formally established on 9 March 1994); has not accepted compulsory ICJ jurisdiction
|
Malta
|
based on English common law and Roman civil law; accepts compulsory ICJ jurisdiction, with reservations
|
Man, Isle of
|
English common law and Manx statute
|
Marshall Islands
|
based on adapted Trust Territory laws, acts of the legislature, municipal, common, and customary laws
|
Martinique
|
French legal system
|
Mauritania
|
a combination of Shari'a (Islamic law) and French civil law
|
Mauritius
|
based on French civil law system with elements of English common law in certain areas
|
Mayotte
|
French law
|
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
|
Midway Islands
|
the laws of the US, where applicable, apply
|
Moldova
|
based on civil law system; Constitutional Court reviews legality of legislative acts and governmental decisions of resolution; it is unclear if Moldova accepts compulsory ICJ jurisdiction but accepts many UN and Organization for Security and Cooperation in Europe (OSCE) documents
|
Monaco
|
based on French law; has not accepted compulsory ICJ jurisdiction
|
Mongolia
|
blend of Soviet, German, and US systems that combine "continental" or "civil" code and case-precedent; constitution ambiguous on judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
|
Montserrat
|
English common law and statutory law
|
Morocco
|
based on Islamic law and French and Spanish civil law system; judicial review of legislative acts in Constitutional Chamber of Supreme Court
|
Mozambique
|
based on Portuguese civil law system and customary law
|
Namibia
|
based on Roman-Dutch law and 1990 constitution
|
Nauru
|
acts of the Nauru Parliament and British common law
|
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
|
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
|
the 1988 Matignon Accords grant substantial autonomy to the islands; formerly under French law
|
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
|
Niger
|
based on French civil law system and customary law; has not accepted compulsory ICJ jurisdiction
|
Nigeria
|
based on English common law, Islamic Shariah law (only in some northern states), and traditional law
|
Niue
|
English common law
note: Niue is self-governing, with the power to make its own 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
|
Palmyra Atoll
|
the laws of the US, where applicable, apply
|
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
|
Paraguay
|
based on Argentine codes, Roman law, and French codes; judicial review of legislative acts in Supreme Court of Justice
|
Peru
|
based on civil law system; has not accepted compulsory ICJ jurisdiction
|
Philippines
|
based on Spanish and Anglo-American law; accepts compulsory ICJ jurisdiction, with reservations
|
Pitcairn Islands
|
local island by-laws
|
Poland
|
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
|
Portugal
|
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
|
discretionary system of law controlled by the amir, although civil codes are being implemented; Islamic law dominates family and personal matters
|
Reunion
|
French law
|
Romania
|
former mixture of civil law system and communist legal theory; is now based on the constitution of France's Fifth Republic
|
Russia
|
based on civil law system; judicial review of legislative acts
|
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 Helena
|
NA
|
Saint Kitts and Nevis
|
based on English common law
|
Saint Lucia
|
based on English common law
|
Saint Pierre and Miquelon
|
French law with special adaptations for local conditions, such as housing and taxation
|
Saint Vincent and the Grenadines
|
based on English common law
|
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 Islamic 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; has not accepted compulsory ICJ jurisdiction
|
Serbia and Montenegro
|
based on civil law system
|
Seychelles
|
based on English common law, French civil law, and customary law
|
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; has not accepted compulsory ICJ jurisdiction; 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
|
Solomon Islands
|
English common law, which is widely disregarded
|
Somalia
|
no national system; Shari'a and secular courts are in some localities
|
South Africa
|
based on Roman-Dutch law and English common law; accepts compulsory ICJ jurisdiction, with reservations
|
South Georgia and the 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; has not accepted compulsory ICJ jurisdiction
|
Sri Lanka
|
a highly complex mixture of English common law, Roman-Dutch, Muslim, Sinhalese, and customary law; has not accepted compulsory ICJ jurisdiction
|
Sudan
|
based on English common law and Islamic law; as of 20 January 1991, the now defunct Revolutionary Command Council imposed Islamic law in the northern states; Islamic law applies to all residents of the northern states regardless of their religion; some separate religious courts; accepts compulsory ICJ jurisdiction, with reservations
|
Suriname
|
based on Dutch legal system incorporating French penal theory
|
Svalbard
|
NA
|
Swaziland
|
based on South African Roman-Dutch law in statutory courts and Swazi traditional law and custom in traditional courts; has not accepted compulsory ICJ jurisdiction
|
Sweden
|
civil law system influenced by customary law; accepts compulsory ICJ jurisdiction, with reservations
|
Switzerland
|
civil law system influenced by customary law; judicial review of legislative acts, except with respect to federal decrees of general obligatory character; accepts compulsory ICJ jurisdiction, with reservations
|
Syria
|
based on Islamic law and civil law system; special religious courts; has not accepted compulsory ICJ jurisdiction
|
Taiwan
|
based on civil law system; accepts compulsory ICJ jurisdiction, with reservations
|
Tajikistan
|
based on civil law system; no judicial review of legislative acts
|
Tanzania
|
based on English common law; judicial review of legislative acts limited to matters of interpretation; has not accepted compulsory ICJ jurisdiction
|
Thailand
|
based on civil law system, with influences of common law; has not accepted compulsory ICJ jurisdiction
|
Togo
|
French-based court system
|
Tokelau
|
New Zealand and local statutes
|
Tonga
|
based on English law
|
Trinidad and Tobago
|
based on English common law; judicial review of legislative acts in the Supreme Court; has not accepted compulsory ICJ jurisdiction
|
Tromelin Island
|
the laws of France, where applicable, apply
|
Tunisia
|
based on French civil law system and Islamic law; some judicial review of legislative acts in the Supreme Court in joint session
|
Turkey
|
civil law system derived from various European continental legal systems; accepts compulsory ICJ jurisdiction, with reservations; note - member of the European Court of Human Rights (ECHR), although Turkey claims limited derogations on the ratified European Convention on Human Rights
|
Turkmenistan
|
based on civil law system
|
Turks and Caicos Islands
|
based on laws of England and Wales, with a few adopted from Jamaica and The Bahamas
|
Tuvalu
|
NA
|
Uganda
|
in 1995, the government restored the legal system to one based on English common law and customary law; accepts compulsory ICJ jurisdiction, with reservations
|
Ukraine
|
based on civil law system; judicial review of legislative acts
|
United Arab Emirates
|
federal court system introduced in 1971; applies to all emirates except Dubayy (Dubai) and Ra's al Khaymah, which are not fully integrated into the federal system; all emirates have secular courts to adjudicate criminal, civil, and commercial matters and Islamic courts to review family and religious disputes
|
United Kingdom
|
common law tradition with early Roman and modern continental influences; has judicial review of Acts of Parliament under the Human Rights Act of 1998; accepts compulsory ICJ jurisdiction, with reservations
|
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; judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations
|
Uruguay
|
based on Spanish civil law system; accepts compulsory ICJ jurisdiction
|
Uzbekistan
|
evolution of Soviet civil law; still lacks independent judicial system
|
Vanuatu
|
unified system being created from former dual French and British systems
|
Venezuela
|
based on organic laws as of July 1999; open, adversarial court system; has not accepted compulsory ICJ jurisdiction
|
Vietnam
|
based on communist legal theory and French civil law system
|
Virgin Islands
|
based on US laws
|
Wake Island
|
the laws of the US, where applicable, apply
|
Wallis and Futuna
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French legal system
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World
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all members of the UN are parties to the statute that established the International Court of Justice (ICJ) or World Court
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Yemen
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based on Islamic law, Turkish law, English common law, and local tribal customary law; has not accepted compulsory ICJ jurisdiction
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Zambia
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based on English common law and customary law; judicial review of legislative acts in an ad hoc constitutional council; has not accepted compulsory ICJ jurisdiction
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Zimbabwe
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mixture of Roman-Dutch and English common law
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