The three major legal systems of the world today consist of civil law, common law and religious law. Civil law or Romano-Germanic law or Continental law is the predominant system of law in the world. Common law refers to law and the corresponding legal system developed through decisions of courts and similar tribunals rather than through legislative statutes or executive In some Religions law can be thought of as the ordering principle of Reality; Knowledge as revealed by God defining and governing all human affairs However, each country (see State law) often develops variations on each system or incorporates many other features into the system. State law in the United States, is the Law of each separate U
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Civil law is the most widespread system of law in the world. Civil law or Romano-Germanic law or Continental law is the predominant system of law in the world. For the Canaanite sun godess see Shemesh Shamash was the common Akkadian name of the Sun-god and god of justice in Babylonia Hammurabi ( Akkadian from Amorite ˤAmmurāpi, "the kinsman is a healer" from ˤAmmu, "paternal kinsman" and Rāpi The Code of Hammurabi ( Codex Hammurabi) is the best-preserved ancient Law code, created ca Law is a system of rules enforced through a set of Institutions used as an instrument to underpin civil obedience politics economics and society It is also known as European Continental law. The central source of law that is recognised as authoritative are codifications in a constitution or statute passed by legislature, to amend a code. In Law, codification is the process of collecting and restating the law of a Jurisdiction in certain areas usually by subject forming a Legal code. A constitution is a system for government often Codified as a written document that establishes the rules and principles of an autonomous political entity A statute is a formal written enactment of a Legislative authority that governs a Country, State, City, or County. A legislature is a type of representative Deliberative assembly with the power to create amend and change Laws The law created by a legislature is called Legislation Civil law systems mainly derive from the Roman Empire, and more particularly, the Corpus Juris Civilis issued by the Emperor Justinian ca. The Roman Empire was the post-Republican phase of the ancient Roman civilization, characterised by an autocratic form of government and large territorial The Corpus Juris Civilis ("Body of Civil Law" is the modern name for a collection of fundamental works in Jurisprudence, issued from 529 Flavius Petrus Sabbatius Iustinianus ( Greek: Φλάβιος Πέτρος Σαββάτιος Ιουστινιανός; known in English as Justinian I or 529AD. This was an extensive reform of the law in the Eastern Empire, bringing it together into codified documents. Civil law was also partly influenced by religious laws such as Canon law and Islamic law. In some Religions law can be thought of as the ordering principle of Reality; Knowledge as revealed by God defining and governing all human affairs Canon law is internal ecclesiastical law governing the Roman Catholic Church, the Eastern Orthodox churches and the Anglican Communion of churches Sharia ( Arabic: ar شريعة) is the body of Islamic Religious law. [1][2] Civil law today, in theory, is interpreted rather than developed or made by judges. Only legislative enactments (rather than judicial precedents) are considered legally binding. A legislature is a type of representative Deliberative assembly with the power to create amend and change Laws The law created by a legislature is called Legislation In Law, the judiciary or judicial system is the system of Courts which administer Justice in the name of the sovereign or State In Common law legal systems, a precedent or authority is a Legal case establishing a principle or rule that a Court or other judicial However, in reality courts do pay attention to previous decisions, especially from higher courts.
Scholars of comparative law and economists promoting the legal origins theory usually subdivide civil law into four distinct groups:
A comprehensive list of countries that base their legal system on a codified civil law follows:
| Country | Description |
|---|---|
| The Civil Code of the Republic of Albania, 1991 really[1] | |
| Based on Portuguese civil law | |
| The Spanish legal tradition had a great influence on the Civil Code of Argentina, basically a work of the Argentinean jurist Dalmacio Vélez Sársfield, who dedicated five years of his life on this task. In Law, codification is the process of collecting and restating the law of a Jurisdiction in certain areas usually by subject forming a Legal code. Portugal, officially the Portuguese Republic (República Portuguesa is a country on the Iberian Peninsula. Spain () or the Kingdom of Spain (Reino de España is a country located mostly in southwestern Europe on the Iberian Peninsula. A civil code is a systematic compilation of laws designed to comprehensively deal with the core areas of Private law. For a topic outline on this subject see List of basic Argentina topics. For a topic outline on this subject see List of basic Argentina topics. JURIST is an online legal news service hosted by the University of Pittsburgh School of Law, written by founder Professor Bernard Hibbitts and a staff of more than Dalmacio Vélez Sársfield ( February 18 1801 &ndash June 30 1875) was an Argentine Lawyer and Politician who The Civil Code came into effect on January 1, 1871. New Year See also New Year The Ancient Romans began their consular year on January 1st since 153 BC Year 1871 ( MDCCCLXXI) was a Common year starting on Sunday (link will display the full calendar of the Gregorian calendar (or a Common Beyond the influence of the Spanish legal tradition, the Argentinian Civil Code was also inspired by the Draft of the Brazilian Civil Code, the Draft of the Spanish Civil Code of 1851, the Napoleonic code and the Chilean Civil Code. |utc_offset = -2 to -4 |time_zone_DST = BRST |utc_offset_DST = -2 to -5 |cctld The Napoleonic Code, or Code Napoléon (originally called the Code civil des Français) is the French Civil code, established under Chile, officially the Republic of Chile ( Spanish:) is a country in South America occupying a long and narrow Coastal strip wedged between the The sources of this Civil Code also include various theoretical legal works, mainly of the great French jurists of the 19th century. This article is about the country For a topic outline on this subject see List of basic France topics. 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. Paraguay, officially the Republic of Paraguay ( Spanish: República del Paraguay; Guaraní: Tetã Paraguái) is one of the only Paraguay, officially the Republic of Paraguay ( Spanish: República del Paraguay; Guaraní: Tetã Paraguái) is one of the only During the second half of the 20th century, the German legal theory became increasingly influential in Argentina. The modern German legal system is a system of Law which is grounded on the principles laid out by the Basic Law for the Federal Republic of Germany, though many of | |
| Courts apply the customary laws of Andorra, supplemented with Roman law and customary Catalan law. [3] | |
| Civil Code of the Republic of Armenia | |
| Based on Dutch civil law | |
| The Allgemeines bürgerliches Gesetzbuch (ABGB) of 1811 | |
| Influenced by the Napoleonic Code | |
| Influenced by the Napoleonic Code | |
| Civil Law system influenced mostly by Germanic and Austro-Hungarian law systems | |
| Derived from the Portuguese civil law | |
| Civil Law system influenced by Germanic and Roman law systems | |
| based on civil law system; derived from Soviet and continental civil code legal principles. The Netherlands ( Dutch:, ˈnedərlɑnt is the European part of the Kingdom of the Netherlands, which consists of the Netherlands the Netherlands The Allgemeines bürgerliches Gesetzbuch ( ABGB) is the Civil Code of Austria, which was enacted in 1811 after about 40 years of preparatory works The legal system of Azerbaijan is based around civil law. As the country was a republic of the Soviet Union until 1991, its legal history has The law of Belgium is very similar to that of neighboring France, with Belgium having adopted the Napoleonic code which governs French society The Napoleonic Code, or Code Napoléon (originally called the Code civil des Français) is the French Civil code, established under The Napoleonic Code, or Code Napoléon (originally called the Code civil des Français) is the French Civil code, established under Brazilian law derives from Portuguese civil law and is based on statutes and partly and more recently súmula vinculante ( Stare decisis Portugal, officially the Portuguese Republic (República Portuguesa is a country on the Iberian Peninsula. Bulgarian law is a largely civil, as opposed to a common, law system based on Epitomes in the French and German systems Law of the People's Republic of China is the legal regime of the People's Republic of China, with the separate legal traditions and systems of Mainland China, | |
| Based on Portuguese civil law | |
| The Spanish legal tradition exercised an especially great influence on the civil code of Chile. Portugal, officially the Portuguese Republic (República Portuguesa is a country on the Iberian Peninsula. A civil code is a systematic compilation of laws designed to comprehensively deal with the core areas of Private law. Chile, officially the Republic of Chile ( Spanish:) is a country in South America occupying a long and narrow Coastal strip wedged between the 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 (1861) and Colombia (1873) constituted faithful reproductions of the Chilean code, but for very few exceptions. For a topic outline on this subject see List of basic Ecuador topics. Colombia (kəˈlʌmbɪə officially the Republic of Colombia () is a country in northwestern South America. The compiler of the Civil Code of Chile, 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. Andrés de Jesús María y José Bello López (b Caracas, Venezuela, d 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. Flavius Petrus Sabbatius Iustinianus ( Greek: Φλάβιος Πέτρος Σαββάτιος Ιουστινιανός; known in English as Justinian I or The Civil Code came into effect on January 1, 1857. New Year See also New Year The Ancient Romans began their consular year on January 1st since 153 BC Click here for Indian Rebellion of 1857 Year 1857 ( MDCCCLVII) was a Common year starting on Thursday (link will display the Its technique is regarded as perfect; it is distinguished for the clarity, logic and cohesiveness of its provisions. As mentioned by Arminjon, Nolde, and Wolff ('Traite de droit comparé', Paris, 1950-1952) Andrés Bello may be regarded as one of the great legislators of mankind. Andrés de Jesús María y José Bello López (b Caracas, Venezuela, d The influence of the Napoleonic code is great; it is observed however that e. The Napoleonic Code, or Code Napoléon (originally called the Code civil des Français) is the French Civil code, established under g. in many provisions of property law, the solutions of the French code civil were put aside in favor of pure Roman law. Property law is the area of Law that governs the various forms of Ownership in Real property (land as distinct from personal or movable possessions Roman law is the legal system of Ancient Rome. As used in the West the term commonly refers to legal developments prior to the Roman/Byzantine state's adopting | |
| Civil code introduced in 1873. Nearly faithful reproduction of the Chilean civil code | |
| First Civil Code (a part of the General Code or Carrillo Code) came into effect in 1841; its text was inspired by the South Peruvian Civil Code of Marshal Andres de Santa Cruz. Chile, officially the Republic of Chile ( Spanish:) is a country in South America occupying a long and narrow Coastal strip wedged between the Andrés de Santa Cruz y Calahumana ( December 5, 1792, La Paz, Bolivia &ndash September 25, 1865, Beauvoir France was President The present Civil Code is into effect since January 1, 1888, and reveals the influenced by the Napoleonic Code and the Spanish Civil Code of 1889 (from its 1851 draft version). New Year See also New Year The Ancient Romans began their consular year on January 1st since 153 BC Year 1888 ( MDCCCLXXXVIII) was a Leap year starting on Sunday (click on link for calendar of the Gregorian calendar (or a The Napoleonic Code, or Code Napoléon (originally called the Code civil des Français) is the French Civil code, established under | |
| Kazneni zakon RH- Great influence of Austro- Hungarian law system | |
| Influenced by Spanish and American law with large elements of Communist legal theory. The substantive and procedural laws of Cuba were later based on the Spanish Civil laws and were influenced by the principles of Marxism-Leninism after that philosophy Socialist law is the official name of the Legal system used in Communist states It is based on the civil law system with major modifications and additions | |
| Scandinavian-German civil law | |
| Based by the Napoleonic Code | |
| Civil code introduced in 1861. The Danish Supreme Court is the highest civil and criminal court responsible for the administration of justice in Denmark. Dominican law theorists make a fundamental distinction between primary sources of law which can give rise to binding legal norms and secondary sources sometimes called authorities The Napoleonic Code, or Code Napoléon (originally called the Code civil des Français) is the French Civil code, established under Nearly faithful reproduction of the Chilean civil code | |
| Based on the Napoleonic code (code civil of 1804) | |
| The Bürgerliches Gesetzbuch of 1900 ("BGB"). Chile, officially the Republic of Chile ( Spanish:) is a country in South America occupying a long and narrow Coastal strip wedged between the In academic terms French law can be divided into two main categories private law (" droit privé " and public law (" droit public " The Napoleonic Code, or Code Napoléon (originally called the Code civil des Français) is the French Civil code, established under The modern German legal system is a system of Law which is grounded on the principles laid out by the Basic Law for the Federal Republic of Germany, though many of The Bürgerliches Gesetzbuch (or BGB) is the Civil code of Germany. The BGB is influenced both by Roman and German law traditions. | |
| The Greek civil code of 1946, highly influenced by the German civil code of 1900 (Bürgerliches Gesetzbuch); the Greek civil code replaced the Byzantine-Roman civil law in effect in Greece since its independence (Νομική Διάταξη της Ανατολικής Χέρσου Ελλάδος, Legal Provision of Eastern Mainland Greece, November 1821: 'Οι Κοινωνικοί Νόμοι των Αειμνήστων Χριστιανών Αυτοκρατόρων της Ελλάδος μόνοι ισχύουσι κατά το παρόν εις την Ανατολικήν Χέρσον Ελλάδα', 'The Social [i. A civil code is a systematic compilation of laws designed to comprehensively deal with the core areas of Private law. The Bürgerliches Gesetzbuch (or BGB) is the Civil code of Germany. e. Civil] Laws of the Dear Departed Christian Emperors of Greece [referring to the Byzantine Emperors] alone are in effect at present in Eastern Mainland Greece') | |
| 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 (in the sense of legislative texts), 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 (the Constitutional Court acting as a 'Tribunal de Amparo', and the Supreme Court acting as a 'Tribunal de Casación') whose theses become binding for lower courts. In certain legal systems (predominantly those of the Spanish-speaking world)an amparo remedy or action is a constitutional proceeding intended to protect a citizen's constitutional | |
| Influenced by the Napoleonic Code | |
| Based on Germanic traditional laws and influenced by Medieval Norwegian and Danish laws. The Napoleonic Code, or Code Napoléon (originally called the Code civil des Français) is the French Civil code, established under | |
| Based on codified Roman law, with elements of the Napoleonic civil code; civil code of 1942 replaced the original one of 1865 | |
| Modeled after European (primarily German) civil law system. Roman law is the legal system of Ancient Rome. As used in the West the term commonly refers to legal developments prior to the Roman/Byzantine state's adopting The Napoleonic Code, or Code Napoléon (originally called the Code civil des Français) is the French Civil code, established under Law of Japan was historically heavily influenced by Chinese law and developed independently during the Edo period through texts such as Kujikata Osadamegaki Japanese civil code of 1895. | |
| Largely influenced by Germany, medium influences from Russian and Soviet law. | |
| Modeled after French civil law | |
| Modeled after Dutch civil law | |
| Influenced by the Napoleonic Code | |
| Based on the Portuguese strand of the continental tradition, itself much influenced by Germany; also influenced by the law of the PRC | |
| "The origins of Mexico's legal system are both ancient and classical, based on the Greek, Roman and French legal systems, and the Mexican system shares more in common with other legal systems throughout the world (especially those in Latin America and most of continental Europe). Lithuanian law is a part of a Legal system of Lithuania. It is largely civil, as opposed to a common, law system based on Epitomes The Napoleonic Code, or Code Napoléon (originally called the Code civil des Français) is the French Civil code, established under Macau law is broadly based on Portuguese Law, and therefore part of the civil law tradition of Continental European legal systems China ( Wade-Giles ( Mandarin) Chung¹kuo² is a cultural region, an ancient Civilization, and depending on perspective a National . . " From: http://www.mexonline.com/lawreview.htm Jaime B. Berger Stender Attorney at Law author, Tijuana, B. C. , Mexico | |
| Influenced by the Napoleonic Code | |
| Scandinavian-German civil law. The Netherlands is a civil law country Its laws are written and the application of Customary law is exceptional The Napoleonic Code, or Code Napoléon (originally called the Code civil des Français) is the French Civil code, established under King Magnus VI the Lawmender unified the regional laws into a single code of law for the whole kingdom in 1274. Magnus Lagabøte ( old Norse Magnús lagabœtir, English Magnus the law-mender) or Magnus Håkonsson ( old Norse This was replaced by Christian V's Norwegian Code of 1687. Christian V ( 15 April 1646 in Flensburg &ndash 25 August 1699 in Copenhagen) was king of Denmark and | |
| The Paraguayan Civil Code in force since 1987 is largely influenced by the Napoleonic Code and the Argentinian Code | |
| The Polish Civil Code in force since 1965 | |
| Influenced by the Napoleonic Code and later by the German Civil Law | |
| Based on the Napoleonic Code | |
| A Civil Law system influenced mostly by Germanic and Austro-Hungarian law systems | |
| Influenced by the Napoleonic Code | |
| Scandinavian-German civil law. The Polish law, or Legal system in Poland. has been developing since the first centuries of Polish history, over 1000 years ago The Portuguese legal system is a civil law or continental legal system based on Roman law. The Napoleonic Code, or Code Napoléon (originally called the Code civil des Français) is the French Civil code, established under The Law of the Republic of China is the legal regime of the Republic of China (also known as Taiwan) The Napoleonic Code, or Code Napoléon (originally called the Code civil des Français) is the French Civil code, established under The primary and fundamental statement of laws in the Russian Federation is the Constitution of the Russian Federation. Spanish law is the term used to describe the legislation which is in force in the Kingdom of Spain, which is understood to mean Spanish territory its waters consulates and The Napoleonic Code, or Code Napoléon (originally called the Code civil des Français) is the French Civil code, established under 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 is indeed worth mentioning that it assimilated very few elements of foreign laws whatsoever. It is also interesting that 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 the Old German 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. | |
| The Zivilgesetzbuch of 1908 and 1912 (obligations; fifth book) | |
| Modeled after the Swiss civil law (Zivilgesetzbuch) of 1907; this has been a conscious choice of Kemal Atatürk, the founder of the modern Turkish state, in order to abolish the Islamic law (Sharia), aiming at westernizing the country | |
| Civil Code of Ukraine of 2004 | |
| based on principles of Code of Canon Law | |
| Communist legal theory and French civil law |
Common law and equity are systems of law whose sources are the decisions in cases by judges. The Zivilgesetzbuch (ZGB german, Code civil (CC french or Codice civile (CC italian is the Swiss Civil code The basics of the legal system in the Republic of Turkey are laid out in Articles 138 to 160 of the 1982 Constitution. Switzerland (English pronunciation; Schweiz Swiss German: Schwyz or Schwiiz Suisse Svizzera Svizra officially the Swiss Confederation The Zivilgesetzbuch (ZGB german, Code civil (CC french or Codice civile (CC italian is the Swiss Civil code Mustafa Kemal Atatürk (19 May 1881 &ndash 10 November 1938 was an army officer revolutionary Statesman Turkey (Türkiye known officially as the Republic of Turkey ( is a Eurasian Country that stretches Sharia ( Arabic: ar شريعة) is the body of Islamic Religious law. Sharia ( Arabic: ar شريعة) is the body of Islamic Religious law. Ukraine is a civil law country Laws are written down the application of Customary law is the exception and the role of Case law Canon Law, the Ecclesiastical law of the Catholic Church, is a fully developed legal system with all the necessary elements courts lawyers judges a fully articulated Law of Vietnam is based on Communist legal theory and French civil law. Communism is a Socioeconomic structure that promotes the establishment of an egalitarian, classless, stateless Society based In academic terms French law can be divided into two main categories private law (" droit privé " and public law (" droit public " Common law refers to law and the corresponding legal system developed through decisions of courts and similar tribunals rather than through legislative statutes or executive Equity is the name given to the set of legal principles in jurisdictions following the English common law tradition which supplement strict rules of law where A judge, or justice, is an Official who presides over a Court of law Alongside, every system will have a legislature that passes new laws and statutes, however these do not amend a collected and codified body of law. A legislature is a type of representative Deliberative assembly with the power to create amend and change Laws The law created by a legislature is called Legislation Common law developed in England, influenced by the Norman conquest of England which introduced legal concepts from Norman law and Islamic law. England is a Country which is part of the United Kingdom. Its inhabitants account for more than 83% of the total UK population whilst its mainland Norman law refers to the customary law of Normandy which developed between the 10th and 13th centuries following the establishment of the Sharia ( Arabic: ar شريعة) is the body of Islamic Religious law. [2] Common law was later inherited by the Commonwealth of Nations, and almost every former colony of the British Empire (Malta being an exception). The British Empire was the largest empire in history and for over a century was the foremost global power. Malta, officially the Republic of Malta (Repubblika ta' Malta is a European Microstate, comprising an Archipelago of three islands The doctrine of stare decisis or precedent by courts is the major difference to codified civil law systems. Stare decisis is a common law doctrine under which judges are obligated to follow the precedents established in prior decisions In Common law legal systems, a precedent or authority is a Legal case establishing a principle or rule that a Court or other judicial
Common law is currently in practice in Ireland, most of the United Kingdom (England and Wales and Northern Ireland), Australia, India, South Africa, Canada (excluding Quebec), Hong Kong and the United States (excluding Louisiana) and many more places. The Republic of Ireland has a Common law Legal system with a written constitution which provides for a parliamentary democracy based on the British parliamentary system The United Kingdom of Great Britain and Northern Ireland, commonly known as the United Kingdom, the UK or Britain,is a Sovereign state located History The Roman occupation of Britain was the first period in which the area of present-day England and Wales was administered as a single unit (with the exception Northern Ireland (Tuaisceart Éireann Ulster Scots: Norlin Airlann) is a Country within the United Kingdom, lying in the northeast of The law of Australia consists of the Australian Common law (which is based on the English common law) federal laws enacted by the Parliament The Law of South Africa has a 'hybrid' or 'mixed' legal system, made of the interweaving of a number of distinct legal traditions a civil law system inherited from its Dutch The Canadian legal system has its foundation in the British Common law system inherited from being a part of the Commonwealth. The law of the United States was originally largely derived from the Common law system of English law, which was in force at the time of the Revolutionary In addition to these countries, several others have adapted the common law system into a mixed system. For example, Pakistan and Nigeria operate largely on a common law system, but incorporate religious law. Pakistan () officially the Islamic Republic of Pakistan, is a country located in South Asia, Southwest Asia, Middle East and Nigeria, officially named the Federal Republic of Nigeria, is a federal Constitutional republic comprising thirty-six states and one Federal
In the European Union the Court of Justice takes an approach mixing civil law (based on the treaties) with an attachment to the importance of case law. The European Union ( EU) is a political and economic union of twenty-seven member states, located primarily in Case law' (also known as decisional law or judicial precedent) is that body of reported Judicial opinions in countries that have Common law One of the most fundamental documents to shape common law is Magna Carta[4] which placed limits on the power of the English Kings. Magna Carta ( Latin for Great Charter, literally " Great Paper " also called Magna Carta Libertatum ( Great Charter of Freedoms It served as a kind of medieval bill of rights for the aristocracy and the judiciary who developed the law.
| Country | Description |
|---|---|
| based on English common law | |
| based on English common law | |
| based on English common law | |
| based on English common law | |
| based on English common law | |
| based on English common law | |
| based on English common law, except in | |
| based on English common law | |
| primarily common law, with early Roman and some modern continental influences | |
| based on English common law | |
| based on English common law | |
| based on English common law | |
| principally based on English common law | |
| based on Irish law before 1922, which was itself based on English common law | |
| based on English common law | |
| based on English common law | |
| based on U.S. Law | |
| based on English common law | |
| based on English common law | |
| Northern Ireland | based on Irish law before 1921, which was itself based on English common law |
| based on U.S. Law | |
| based on English common law | |
| based on English common law | |
| based on English common law | |
| based on English common law | |
| based on English common law | |
| based on English common law | |
| Federal court system based on English common law Unlike the rest of the other United States, the state legal system of State of Louisiana (USA) is based upon napoleonic code(see below) |
Religious law refers to the notion of a religious system or document being used as a legal source, though the methodology used varies. English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the The law of Australia consists of the Australian Common law (which is based on the English common law) federal laws enacted by the Parliament English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the The law of the British Virgin Islands is a combination of Common law and statute and is based heavily upon English law. English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the The Canadian legal system has its foundation in the British Common law system inherited from being a part of the Commonwealth. English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the Quebec (kwɨˈbɛk In academic terms French law can be divided into two main categories private law (" droit privé " and public law (" droit public " English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the Common law refers to law and the corresponding legal system developed through decisions of courts and similar tribunals rather than through legislative statutes or executive Roman law is the legal system of Ancient Rome. As used in the West the term commonly refers to legal developments prior to the Roman/Byzantine state's adopting Continental Europe, also referred to as mainland Europe or simply the Continent, is the Continent of Europe, explicitly excluding European English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the China ( Wade-Giles ( Mandarin) Chung¹kuo² is a cultural region, an ancient Civilization, and depending on perspective a National English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the The Republic of Ireland has a Common law Legal system with a written constitution which provides for a parliamentary democracy based on the British parliamentary system English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the The law of the United States was originally largely derived from the Common law system of English law, which was in force at the time of the Revolutionary English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the The law of New Zealand can be found in several sources The primary sources of New Zealand law are statutes enacted by the New Zealand Parliament and decisions of the New English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the Northern Ireland law concerns the Legal system of Northern Ireland. English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the The law of the United States was originally largely derived from the Common law system of English law, which was in force at the time of the Revolutionary English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the The law of the United States was originally largely derived from the Common law system of English law, which was in force at the time of the Revolutionary The United States federal courts are the system of Courts organized under the Constitution and laws of the Federal government of the United States The State of Louisiana ( or, État de Louisiane, pronounced) is a state located in the southern region of the United States of America In some Religions law can be thought of as the ordering principle of Reality; Knowledge as revealed by God defining and governing all human affairs For example, the use of Jewish 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 civil codes; and Islamic Sharia law (and Fiqh jurisprudence) is based on legal precedent and reasoning by analogy (Qiyas), and is thus considered a precursor to common law. Halakha ( הלכה; alternative transliterations include Halocho and Halacha) is the collective body of Jewish Religious law Canon law is internal ecclesiastical law governing the Roman Catholic Church, the Eastern Orthodox churches and the Anglican Communion of churches A civil code is a systematic compilation of laws designed to comprehensively deal with the core areas of Private law. Sharia ( Arabic: ar شريعة) is the body of Islamic Religious law. Fiqh ( Arabic: فقه, fɪqəh is Islamic Jurisprudence. Fiqh is an expansion of the Sharia Islamic law—based directly on the In Common law legal systems, a precedent or authority is a Legal case establishing a principle or rule that a Court or other judicial Analogy is both the cognitive process of transferring Information from a particular subject (the analogue or source to another particular subject (the target and In Sunni Islamic jurisprudence,the qiyas ( Arabic قياس is the process of analogical reasoning in which the teachings of the Quran are compared Common law refers to law and the corresponding legal system developed through decisions of courts and similar tribunals rather than through legislative statutes or executive [5]
The main kinds of religious law are Sharia in Islam, Halakha in Judaism, and Canon law in some Christian groups. Sharia ( Arabic: ar شريعة) is the body of Islamic Religious law. For other meanings including people named 'Islam' see Islam (disambiguation. Halakha ( הלכה; alternative transliterations include Halocho and Halacha) is the collective body of Jewish Religious law Judaism (from the Greek Ioudaïsmos, derived from the Hebrew יהודה Yehudah, " Judah " in Hebrew יַהֲדוּת Yahedut Canon law is internal ecclesiastical law governing the Roman Catholic Church, the Eastern Orthodox churches and the Anglican Communion of churches A Christian is a person who adheres to Christianity, a monotheistic Religion centered on the life and teachings of Jesus of Nazareth 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. A moral is a message conveyed or a lesson to be learned from a story or event The latter was particularly common during the Middle Ages.
The Islamic legal system of Sharia (Islamic law) and Fiqh (Islamic jurisprudence) 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. For other meanings including people named 'Islam' see Islam (disambiguation. Sharia ( Arabic: ar شريعة) is the body of Islamic Religious law. Fiqh ( Arabic: فقه, fɪqəh is Islamic Jurisprudence. Fiqh is an expansion of the Sharia Islamic law—based directly on the In some Religions law can be thought of as the ordering principle of Reality; Knowledge as revealed by God defining and governing all human affairs Common law refers to law and the corresponding legal system developed through decisions of courts and similar tribunals rather than through legislative statutes or executive Civil law or Romano-Germanic law or Continental law is the predominant system of law in the world. [6] During the Islamic Golden Age, classical Islamic law had a fairly significant influence on the development of common law,[2] and also influenced the development of several civil law institutions. Institutions are structures and mechanisms of Social order and Cooperation governing the Behavior of a Set of Individuals [1]
The Halakha is followed by orthodox and conservative Jews in both ecclesiastical and civil relations. Orthodox Judaism is the formulation of Judaism that adheres to a relatively strict interpretation and application of the laws and ethics first canonized Conservative Judaism (also known as Masorti Judaism in Israel and Europe) is a modern stream of Judaism that arose out 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. 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. The Kingdom of Saudi Arabia, KSA ( المملكة العربية السعودية, al-Mamlaka al-ʻArabiyya as-Suʻūdiyya) or Suudi For a topic outline on this subject see List of basic Iran topics. It can relate to all aspects of civil law, including property rights, contracts or public law.
Canon law also differs from other religious laws, properly speaking, because it is not found in revelation. Canon law is internal ecclesiastical law governing the Roman Catholic Church, the Eastern Orthodox churches and the Anglican Communion of churches 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 Roman Catholic Church, the Eastern Orthodox Church and the Anglican Communion. The Eastern Orthodox Church is the second largest single Christian Communion in the world See also Anglicanism The Anglican Communion is an international association of national Anglican churches Canon law is amended and adapted by the legislative authority of the church, such as councils of bishops, single bishops for their respective sees, the Pope for the entire Catholic Church, and the British Parliament for the Church of England.
| Country | Description |
|---|---|
| South African law (a mixed system) transferred uno acto through a proclamation of reception | |
| Based on English common law (Cyprus was a British colony 1878-1960), with admixtures of French and Greek civil and public law, Italian civil law, Indian contract law, Greek Orthodox canon law, Muslim religious law, and Ottoman civil law. The legal system of Bangladesh is primarily in accordance with the English legal system although since 1947, the legal scenario and the laws of Bangladesh A nationwide judicial system in Iran was first implemented and established by Ali Akbar Davar and some of his contemporaries such as Abdolhossein Teymourtash under Reza English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the Greece (Ελλάδα transliterated: Elláda, historically, Ellás,) officially the Hellenic Republic (Ελληνική Δημοκρατία Italy (Italia officially the Italian Republic, (Repubblica Italiana is located on the Italian Peninsula in Southern Europe, and on the two largest India, officially the Republic of India (भारत गणराज्य inc-Latn Bhārat Gaṇarājya; see also other Indian languages) is a country The Greek Orthodox Church ( Greek: Ἑλληνορθόδοξη Ἐκκλησία Hellēnorthódoxē Ekklēsía) is formed by several autocephalous churches A Muslim (مسلم pronounced Muslim, not Muzlim) is an adherent of the Religion The Ottoman Empire (1299–1923 ( Old Ottoman Turkish: دولتْ علیّه عثمانیّه Devlet-i Âliye-yi Osmâniyye, Late Ottoman and Modern Turkish | |
| Originally (1948) based on English common law; in the process, influenced by German civil law—for instance, between 1962 and 1981, the Knesset issued twenty (20) wide-ranging laws, which were clearly influenced by European continental law, and were in the form of codes. Law of Israel combines Common law and civil law. Sources of Israeli law Israeli law draws on the following sources The Mecelle For Beit Knesset a Jewish Place of worship, see Synagogue. The Knesset (כנסת lit Religious law plays a role, especially in matters of personal status and family law, and judicial and legislative decisions take into account Jewish law (halakhah) on occasion. Halakha ( הלכה; alternative transliterations include Halocho and Halacha) is the collective body of Jewish Religious law [7] | |
| South African law (a mixed system) transferred uno acto through a proclamation of reception | |
| Based on the French Napoleonic Code; the modern legal system of the state of Louisiana has its origin in the Louisiana Purchase (i. The Napoleonic Code, or Code Napoléon (originally called the Code civil des Français) is the French Civil code, established under The State of Louisiana ( or, État de Louisiane, pronounced) is a state located in the southern region of the United States of America For the film see Louisiana Purchase (film. The Louisiana Purchase (French Vente de la Louisiane "Louisiana Sale" e. the sale of Louisiana—not coterminous with the present eponymous state—by Napoleon to the United States of America in 1803), while federal laws (based on common law) are in effect in Louisiana as well. | |
| Initially based on Roman Law and eventually progressed to the Code de Rohan, Code Napoleon with influences from Italian Civil Law. Roman law is the legal system of Ancient Rome. As used in the West the term commonly refers to legal developments prior to the Roman/Byzantine state's adopting The Napoleonic Code, or Code Napoléon (originally called the Code civil des Français) is the French Civil code, established under English common law however is also a source of Maltese Law, most notably in Public Law | |
| South African law (a mixed system) transferred uno acto through a proclamation of reception | |
| Based on Spanish law; influenced by U. English law is the legal system of England and Wales, and is the basis of Common law legal systems used in most Commonwealth countriesand the Public law is a theory of law governing the relationship between Individuals ( Citizens companies) and the State. S. common law after 1898 Spanish and Philippine-American Wars. | |
| Based on Spanish law; influenced by U. S. common law after 1898 (victory of the U. S. over Spain in the Spanish-American war of 1898 and cession of Puerto Rico to the U. S. ) | |
| After the defeat of the French in the battle at the Plains of Abraham, the British allowed them to keep their language (French), their religion (Roman Catholicism), and their legal system (civil law). Quebec law is unique in Canada because Quebec is the only province in Canada to have a civil law system This article is about the country For a topic outline on this subject see List of basic France topics. The Plains of Abraham is a historic 108- Acre (44- Hectare) Plateau within The Battlefields Park in Quebec City, Canada, See also Kingdom of Great Britain Great Britain (Breatainn Mhòr Prydain Fawr Breten Veur Graet Breetain is the larger of the two main islands French ( français,) is a Romance language spoken around the world by 118 million people as a native language and by about 180 to 260 million people Civil law or Romano-Germanic law or Continental law is the predominant system of law in the world. However, as Quebec is part of the Canadian Confederation, English-based laws applied at the federal level are in effect in Quebec also. Quebec (kwɨˈbɛk | |
| based on Roman and continental law, with common law elements dating back to the High Middle Ages | |
| An amalgam of English common law and Roman-Dutch civil law as well as Customary Law. Scots law is a unique legal system with an ancient basis in Roman law. Roman law is the legal system of Ancient Rome. As used in the West the term commonly refers to legal developments prior to the Roman/Byzantine state's adopting Scottish legal institutions in the High Middle Ages are for the purposes of this article the informal and formal systems which governed and helped to manage Scottish society between the The Law of South Africa has a 'hybrid' or 'mixed' legal system, made of the interweaving of a number of distinct legal traditions a civil law system inherited from its Dutch England is a Country which is part of the United Kingdom. Its inhabitants account for more than 83% of the total UK population whilst its mainland Common law refers to law and the corresponding legal system developed through decisions of courts and similar tribunals rather than through legislative statutes or executive Roman Dutch law is a Legal system based on Roman law as applied in the Netherlands in the 17th and 18th century In Law, custom can be described as the established patterns of behavior that can be objectively verified within a particular social setting | |
| An amalgam of English common law, Roman-Dutch civil law and Customary Law | |
| South African law (a mixed system) transferred uno acto through a proclamation of reception | |
| South African law (a mixed system) transferred uno acto through a proclamation of reception |
| Country | Description |
|---|---|
| Based on Islamic law and French civil law system | |
| Based on civil law of Holland and adat (cultural law of Indonesia) | |
| Based on Islamic law and French and Spanish civil law system |
| Country | Description |
|---|---|
| based on English common law, separate personal law codes apply to Muslims, Christians, and Hindus, but criminal penal law is uniform | |
| based on English common law, personal law based on sharia law applies to Muslims | |
| based on English Common Law, some Islamic Law applications in inheritance. England is a Country which is part of the United Kingdom. Its inhabitants account for more than 83% of the total UK population whilst its mainland Common law refers to law and the corresponding legal system developed through decisions of courts and similar tribunals rather than through legislative statutes or executive Roman Dutch law is a Legal system based on Roman law as applied in the Netherlands in the 17th and 18th century In Law, custom can be described as the established patterns of behavior that can be objectively verified within a particular social setting A Muslim (مسلم pronounced Muslim, not Muzlim) is an adherent of the Religion A Christian is a person who adheres to Christianity, a monotheistic Religion centered on the life and teachings of Jesus of Nazareth A Hindu ( Devanagari: हिन्दू is an adherent of the philosophies and scriptures of Hinduism, a set of religious, Philosophical The law of Malaysia is mainly based on the Common law legal system Sharia ( Arabic: ar شريعة) is the body of Islamic Religious law. A Muslim (مسلم pronounced Muslim, not Muzlim) is an adherent of the Religion Sharia ( Arabic: ar شريعة) is the body of Islamic Religious law. "Heir" and "Heiress" redirect here For the men and women fragrances endorsed by Paris Hilton see Heiress (fragrance. Tribal Law in FATA | |
| based on English common law |
Despite the usefulness of different classifications, every legal system has its own individual identity. Tribal sovereignty refers to the inherent authority of indigenous tribes to govern themselves The Federally Administered Tribal Areas ( FATA) in Pakistan are areas outside the four provinces bordering Afghanistan, comprising a region The legal system of Singapore is based on the English common law system Below are groups of legal systems, categorised by their geography. Geography (from Greek γεωγραφία - geografia) is the study of the Earth and its lands features inhabitants and phenomena Click the "show" buttons on the right for the lists of countries.