COUNTRYLEGAL SYSTEMAfghanistan mixed legal system of civil, customary, and Islamic (sharia) law Akrotiri laws applicable to the Cypriot population are, as far as possible, the same as the laws of the Republic of Cyprus; note - the Sovereign Base Area Administration has its own court system to deal with civil and criminal matters Albania civil law system except in the northern rural areas where customary law known as the "Code of Leke" is still present Algeria mixed legal system of French civil law and Islamic law; judicial review of legislative acts in ad hoc Constitutional Council composed of various public officials including several Supreme Court justices American Samoa mixed legal system of US common law and customary law Andorra mixed legal system of civil and customary law with the influence of canon (religious) law Angola civil legal system based on Portuguese civil law; no judicial review of legislation Anguilla common law based on the English model Antarctica Antarctica is administered through annual meetings - known as Antarctic Treaty Consultative Meetings - which include consultative member nations, non-consultative member nations, observer organizations, and expert organizations; 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; more generally, the Antarctic Treaty area, that is to all areas between 60 and 90 degrees south latitude, is subject to a number of relevant legal instruments and procedures adopted by the states party to the Antarctic Treaty; note - US law, including certain criminal offenses by or against US nationals, such as murder, may apply extraterritoriality; 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 or 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 and Polar Affairs, Room 2665, Department of State, Washington, DC 20520, which reports such plans to other nations as required by the Antarctic Treaty; for more information, contact antarctica@state.gov Antigua and Barbuda common law based on the English model Argentina civil law system based on West European legal systems; note - in mid-2015, Argentina adopted a new civil code, replacing the old one in force since 1871 Armenia civil law system Aruba civil law system based on the Dutch civil code Ashmore and Cartier Islands the laws of the Commonwealth of Australia and the laws of the Northern Territory of Australia, where applicable, apply Australia common law system based on the English model Austria civil law system; judicial review of legislative acts by the Constitutional Court Azerbaijan civil law system Bahamas, The common law system based on the English model Bahrain mixed legal system of Islamic (sharia) law, English common law, Egyptian civil, criminal, and commercial codes; customary law Bangladesh mixed legal system of mostly English common law and Islamic law Barbados English common law; no judicial review of legislative acts Belarus civil law system; note - nearly all major codes (civil, civil procedure, criminal, criminal procedure, family, and labor) were revised and came into force in 1999 and 2000 Belgium civil law system based on the French Civil Code; note - Belgian law continues to be modified in conformance with the legislative norms mandated by the European Union; judicial review of legislative acts Belize English common law Benin civil law system modeled largely on the French system and some customary law Bermuda English common law Bhutan civil law based on Buddhist religious law Bolivia civil law system with influences from Roman, Spanish, canon (religious), French, and indigenous law Bosnia and Herzegovina civil law system; Constitutional Court review of legislative acts Botswana mixed legal system of civil law influenced by the Roman-Dutch model and also customary and common law Bouvet Island the laws of Norway apply where applicable Brazil civil law; note - a new civil law code was enacted in 2002 replacing the 1916 code British Indian Ocean Territory the laws of the UK apply where applicable British Virgin Islands English common law Brunei mixed legal system based on English common law and Islamic law; note - in April 2019, the full sharia penal codes came into force and apply to Muslims and non-Muslims in parallel with present common law codes Bulgaria civil law Burkina Faso civil law based on the French model and customary law Burma mixed legal system of English common law (as introduced in codifications designed for colonial India) and customary law Burundi mixed legal system of Belgian civil law and customary law Cabo Verde civil law system of Portugal Cambodia civil law system (influenced by the UN Transitional Authority in Cambodia) customary law, Communist legal theory, and common law Cameroon mixed legal system of English common law, French civil law, and customary law Canada common law system except in Quebec, where civil law based on the French civil code prevails Cayman Islands English common law and local statutes Central African Republic civil law system based on the French model Chad mixed legal system of civil and customary law Chile civil law system influenced by several West European civil legal systems; judicial review of legislative acts by the Constitutional Tribunal China civil law influenced by Soviet and continental European civil law systems; legislature retains power to interpret statutes; note - in March 2017, the National People's Congress passed a new civil code, the General Rules of Civil Law, which became effective the following October Christmas Island legal system is under the authority of the governor general of Australia and Australian law Clipperton Island the laws of France apply Cocos (Keeling) Islands common law based on the Australian model Colombia civil law system influenced by the Spanish and French civil codes Comoros mixed legal system of Islamic religious law, the French civil code of 1975, and customary law Congo, Democratic Republic of the civil law system primarily based on Belgian law, but also customary and tribal law Congo, Republic of the mixed legal system of French civil law and customary law Cook Islands common law similar to New Zealand common law Coral Sea Islands the common law legal system of Australia applies where applicable Costa Rica civil law system based on Spanish civil code; judicial review of legislative acts in the Supreme Court Cote d'Ivoire civil law system based on the French civil code; judicial review of legislation held in the Constitutional Chamber of the Supreme Court Croatia civil law system influenced by legal heritage of Austria-Hungary; note - Croatian law was fully harmonized with the European Community acquis as of the June 2010 completion of EU accession negotiations Cuba civil law system based on Spanish civil code Curacao based on Dutch civil law Cyprus mixed legal system of English common law and civil law with European law supremacy Czechia new civil code enacted in 2014, replacing civil code of 1964 - based on former Austro-Hungarian civil codes and socialist theory - and reintroducing former Czech legal terminology Denmark civil law; judicial review of legislative acts Dhekelia laws applicable to the Cypriot population are, as far as possible, the same as the laws of the Republic of Cyprus; note - the Sovereign Base Area Administration has its own court system to deal with civil and criminal matters Djibouti mixed legal system based primarily on the French civil code (as it existed in 1997), Islamic religious law (in matters of family law and successions), and customary law Dominica common law based on the English model Dominican Republic civil law system based on the French civil code; Criminal Procedures Code modified in 2004 to include important elements of an accusatory system Ecuador civil law based on the Chilean civil code with modifications; traditional law in indigenous communities Egypt mixed legal system based on Napoleonic civil and penal law, Islamic religious law, and vestiges of colonial-era laws; judicial review of the constitutionality of laws by the Supreme Constitutional Court El Salvador civil law system with minor common law influence; judicial review of legislative acts in the Supreme Court Equatorial Guinea mixed system of civil and customary law Eritrea mixed legal system of civil, customary, and Islamic religious law Estonia civil law system Eswatini mixed legal system of civil, common, and customary law Ethiopia civil law system European Union unique supranational law system in which, according to an interpretive declaration of member-state governments appended to the Treaty of Lisbon, "the Treaties and the law adopted by the Union on the basis of the Treaties have primacy over the law of Member States" under conditions laid down in the case law of the Court of Justice; key principles of EU law include fundamental rights as guaranteed by the Charter of Fundamental Rights and as resulting from constitutional traditions common to the EU's 28-member states; EU law is divided into 'primary' and 'secondary' legislation; primary legislation is derived from the consolidated versions of the Treaty on European Union and the Treaty on the Functioning of the European Union and are the basis for all EU action; secondary legislation - which includes directives, regulations, and decisions - is derived from the principles and objectives set out in the treaties Falkland Islands (Islas Malvinas) English common law and local statutes Faroe Islands the laws of Denmark apply where applicable Fiji common law system based on the English model Finland civil law system based on the Swedish model France civil law; review of administrative but not legislative acts French Polynesia the laws of France, where applicable, apply French Southern and Antarctic Lands the laws of France, where applicable, apply Gabon mixed legal system of French civil law and customary law Gambia, The mixed legal system of English common law, Islamic law, and customary law Georgia civil law system Germany civil law system Ghana mixed system of English common law and customary law Gibraltar the laws of the UK, where applicable, apply Greece civil legal system based on Roman law Greenland the laws of Denmark apply where applicable and Greenlandic law applies to other areas Grenada common law based on English model Guam common law modeled on US system; US federal laws apply Guatemala civil law system; judicial review of legislative acts Guernsey customary legal system based on Norman customary law; includes elements of the French civil code and English common law Guinea civil law system based on the French model Guinea-Bissau mixed legal system of civil law, which incorporated Portuguese law at independence and influenced by Economic Community of West African States (ECOWAS), West African Economic and Monetary Union (UEMOA), African Francophone Public Law, and customary law Guyana common law system, based on the English model, with some Roman-Dutch civil law influence Haiti civil law system strongly influenced by Napoleonic Code Heard Island and McDonald Islands the laws of Australia apply where applicable Holy See (Vatican City) religious legal system based on canon (religious) law Honduras civil law system Hong Kong mixed legal system of common law based on the English model and Chinese customary law (in matters of family and land tenure) Howland Island the laws of the US apply where applicable Hungary civil legal system influenced by the German model Iceland civil law system influenced by the Danish model India common law system based on the English model; separate personal law codes apply to Muslims, Christians, and Hindus; judicial review of legislative acts Indonesia civil law system based on the Roman-Dutch model and influenced by customary law Iran religious legal system based on secular and Islamic law Iraq mixed legal system of civil and Islamic law Ireland common law system based on the English model but substantially modified by customary law; judicial review of legislative acts by Supreme Court Isle of Man the laws of the UK apply where applicable and include Manx statutes Israel mixed legal system of English common law, British Mandate regulations, and Jewish, Christian, and Muslim religious laws Italy civil law system; judicial review of legislation under certain conditions in Constitutional Court Jamaica common law system based on the English model Jan Mayen the laws of Norway apply where applicable Japan civil law system based on German model; system also reflects Anglo-American influence and Japanese traditions; judicial review of legislative acts in the Supreme Court Jarvis Island the laws of the US apply where applicable Jersey the laws of the UK apply where applicable; includes local statutes Johnston Atoll the laws of the US apply where applicable Jordan mixed system developed from codes instituted by the Ottoman Empire (based on French law), British common law, and Islamic law Kazakhstan civil law system influenced by Roman-Germanic law and by the theory and practice of the Russian Federation Kenya mixed legal system of English common law, Islamic law, and customary law; judicial review in the new Supreme Court established by the new constitution Kingman Reef the laws of the US apply where applicable Kiribati English common law supplemented by customary law Korea, North civil law system based on the Prussian model; system influenced by Japanese traditions and Communist legal theory Korea, South mixed legal system combining European civil law, Anglo-American law, and Chinese classical thought Kosovo civil law system; note - the European Union Rule of Law Mission (EULEX) retained limited executive powers within the Kosovo judiciary for complex cases from 2008 to 2018 Kuwait mixed legal system consisting of English common law, French civil law, and Islamic sharia law Kyrgyzstan civil law system, which includes features of French civil law and Russian Federation laws Laos civil law system similar in form to the French system Latvia civil law system with traces of socialist legal traditions and practices Lebanon mixed legal system of civil law based on the French civil code, Ottoman legal tradition, and religious laws covering personal status, marriage, divorce, and other family relations of the Jewish, Islamic, and Christian communities Lesotho mixed legal system of English common law and Roman-Dutch law; judicial review of legislative acts in High Court and Court of Appeal Liberia mixed legal system of common law, based on Anglo-American law, and customary law Libya Libya's post-revolution legal system is in flux and driven by state and non-state entities Liechtenstein civil law system influenced by Swiss, Austrian, and German law Lithuania civil law system; legislative acts can be appealed to the Constitutional Court Luxembourg civil law system Macau civil law system based on the Portuguese model Madagascar civil law system based on the old French civil code and customary law in matters of marriage, family, and obligation Malawi mixed legal system of English common law and customary law; judicial review of legislative acts in the Supreme Court of Appeal Malaysia mixed legal system of English common law, Islamic (sharia) law, and customary law; judicial review of legislative acts in the Federal Court at request of supreme head of the federation Maldives Islamic (sharia) legal system with English common law influences, primarily in commercial matters Mali civil law system based on the French civil law model and influenced by customary law; judicial review of legislative acts in the Constitutional Court Malta mixed legal system of English common law and civil law based on the Roman and Napoleonic civil codes; subject to European Union law Marshall Islands mixed legal system of US and English common law, customary law, and local statutes Mauritania mixed legal system of Islamic and French civil law Mauritius civil legal system based on French civil law with some elements of English common law Mexico civil law system with US constitutional law influence; judicial review of legislative acts Micronesia, Federated States of mixed legal system of common and customary law Midway Islands the laws of the US apply where applicable Moldova civil law system with Germanic law influences; Constitutional Court review of legislative acts Monaco civil law system influenced by French legal tradition Mongolia civil law system influenced by Soviet and Romano-Germanic legal systems; constitution ambiguous on judicial review of legislative acts Montenegro civil law Montserrat English common law Morocco mixed legal system of civil law based on French civil law and Islamic (sharia) law; judicial review of legislative acts by Constitutional Court Mozambique mixed legal system of Portuguese civil law and customary law; note - in rural, apply where applicable predominantly Muslim villages with no formal legal system, Islamic law may be applied Namibia mixed legal system of uncodified civil law based on Roman-Dutch law and customary law Nauru mixed legal system of common law based on the English model and customary law Navassa Island the laws of the US apply where applicable Nepal English common law and Hindu legal concepts; note - new criminal and civil codes came into effect on 17 August 2018 Netherlands civil law system based on the French system; constitution does not permit judicial review of acts of the States General New Caledonia civil law system based on French civil law New Zealand common law system, based on English model, with special legislation and land courts for the Maori Nicaragua civil law system; Supreme Court may review administrative acts Niger mixed legal system of civil law, based on French civil law, Islamic law, and customary law Nigeria mixed legal system of English common law, Islamic law (in 12 northern states), and traditional law Niue English common law Norfolk Island English common law and the laws of Australia North Macedonia civil law system; judicial review of legislative acts Northern Mariana Islands the laws of the US apply, except for customs and some aspects of taxation Norway mixed legal system of civil, common, and customary law; Supreme Court can advise on legislative acts Oman mixed legal system of Anglo-Saxon law and Islamic law Pakistan common law system with Islamic law influence Palau mixed legal system of civil, common, and customary law Palmyra Atoll the laws of the US apply where applicable Panama civil law system; judicial review of legislative acts in the Supreme Court of Justice Papua New Guinea mixed legal system of English common law and customary law Paraguay civil law system with influences from Argentine, Spanish, Roman, and French civil law models; judicial review of legislative acts in Supreme Court of Justice Peru civil law system Philippines mixed legal system of civil, common, Islamic (sharia), and customary law Pitcairn Islands local island by-laws Poland civil law system; judicial review of legislative, administrative, and other governmental acts; constitutional law rulings of the Constitutional Tribunal are final Portugal civil law system; Constitutional Court review of legislative acts Puerto Rico civil law system based on the Spanish civil code and within the framework of the US federal system Qatar mixed legal system of civil law and Islamic (sharia) law (in family and personal matters) Romania civil law system Russia civil law system; judicial review of legislative acts Rwanda mixed legal system of civil law, based on German and Belgian models, and customary law; judicial review of legislative acts in the Supreme Court Saint Barthelemy French civil law Saint Helena, Ascension, and Tristan da Cunha English common law and local statutes Saint Kitts and Nevis English common law Saint Lucia English common law Saint Martin French civil law Saint Pierre and Miquelon French civil law Saint Vincent and the Grenadines English common law Samoa mixed legal system of English common law and customary law; judicial review of legislative acts with respect to fundamental rights of the citizen San Marino civil law system with Italian civil law influences Sao Tome and Principe mixed legal system of civil law based on the Portuguese model and customary law Saudi Arabia Islamic (sharia) legal system with some elements of Egyptian, French, and customary law; note - several secular codes have been introduced; commercial disputes handled by special committees Senegal civil law system based on French law; judicial review of legislative acts in Constitutional Court Serbia civil law system Seychelles mixed legal system of English common law, French civil law, and customary law Sierra Leone mixed legal system of English common law and customary law Singapore English common law Sint Maarten based on Dutch civil law system with some English common law influence Slovakia civil law system based on Austro-Hungarian codes; note - legal code modified to comply with the obligations of Organization on Security and Cooperation in Europe Slovenia civil law system Solomon Islands mixed legal system of English common law and customary law Somalia mixed legal system of civil law, Islamic (sharia) law, and customary law (referred to as Xeer) South Africa mixed legal system of Roman-Dutch civil law, English common law, and customary law South Georgia and South Sandwich Islands the laws of the UK, where applicable, apply Spain civil law system with regional variations Sri Lanka mixed legal system of Roman-Dutch civil law, English common law, Jaffna Tamil customary law, and Muslim personal law Sudan mixed legal system of Islamic law and English common law Suriname civil law system influenced by Dutch civil law; note - a new criminal code was enacted in 2017 Svalbard the laws of Norway where applicable apply; only the laws of Norway made explicitly applicable to Svalbard have effect there; the Svalbard Act and the Svalbard Environmental Protection Act, and certain regulations, apply only to Svalbard; the Spitsbergen Treaty and the Svalbard Treaty grant certain rights to citizens and corporations of signatory nations; as of June 2017, 45 nations had ratified the Svalbard Treaty Sweden civil law system influenced by Roman-Germanic law and customary law Switzerland civil law system; judicial review of legislative acts, except for federal decrees of a general obligatory character Syria mixed legal system of civil and Islamic (sharia) law (for family courts) Taiwan civil law system Tajikistan civil law system Tanzania English common law; judicial review of legislative acts limited to matters of interpretation Thailand civil law system with common law influences Timor-Leste civil law system based on the Portuguese model; note - penal and civil law codes to replace the Indonesian codes were passed by Parliament and promulgated in 2009 and 2011, respectively Togo customary law system Tokelau common law system of New Zealand Tonga English common law Trinidad and Tobago English common law; judicial review of legislative acts in the Supreme Court Tunisia mixed legal system of civil law, based on the French civil code and Islamic (sharia) law; some judicial review of legislative acts in the Supreme Court in joint session Turkey civil law system based on various European legal systems, notably the Swiss civil code Turkmenistan civil law system with Islamic (sharia) law influences Turks and Caicos Islands mixed legal system of English common law and civil law Tuvalu mixed legal system of English common law and local customary law Uganda mixed legal system of English common law and customary law Ukraine civil law system; judicial review of legislative acts United Arab Emirates mixed legal system of Islamic (sharia) law and civil law United Kingdom common law system; has nonbinding judicial review of Acts of Parliament under the Human Rights Act of 1998 United States common law system based on English common law at the federal level; state legal systems based on common law, except Louisiana, where state law is based on Napoleonic civil code; judicial review of legislative acts United States Pacific Island Wildlife Refuges the laws of the US apply where applicable Uruguay civil law system based on the Spanish civil code Uzbekistan civil law system Vanuatu mixed legal system of English common law, French law, and customary law Venezuela civil law system based on the Spanish civil code Vietnam civil law system; note - the civil code of 2005 reflects a European-style civil law Virgin Islands US common law Wake Island US common law Wallis and Futuna French civil law World the legal systems of nearly all countries are generally modeled upon elements of five main types: civil law (including French law, the Napoleonic Code, Roman law, Roman-Dutch law, and Spanish law); common law (including English and US law); customary law; mixed or pluralistic law; and religious law (including Islamic sharia law); an additional type of legal system - international law - governs the conduct of independent nations in their relationships with one another Yemen mixed legal system of Islamic (sharia) law, Napoleonic law, English common law, and customary law Zambia mixed legal system of English common law and customary law Zimbabwe mixed legal system of English common law, Roman-Dutch civil law, and customary law