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  Field Listing - Legal system


Country
Legal system
Afghanistan based on mixed civil and Shari'a law; has not accepted compulsory ICJ jurisdiction
Akrotiri the Sovereign Base Area Administration has its own court system to deal with civil and criminal matters; laws applicable to the Cypriot population are, as far as possible, the same as the laws of the Republic of Cyprus
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 extraterritorially; 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; more generally, access to 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 authorization procedures adopted by the states party to the Antarctic Treaty
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; has not accepted compulsory ICJ jurisdiction
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; has not accepted compulsory ICJ jurisdiction
Bahamas, The based on English common law
Bahrain based on Islamic law and English common law; has not accepted compulsory ICJ jurisdiction
Baker Island the laws of the US, where applicable, apply
Bangladesh based on English common law; has not accepted compulsory ICJ jurisdiction
Barbados English common law; no judicial review of legislative acts; accepts compulsory ICJ jurisdiction, with reservations
Belarus based on civil law system; has not accepted compulsory ICJ jurisdiction
Belgium based on 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; has not accepted compulsory ICJ jurisdiction
Botswana based on Roman-Dutch law and local customary law; judicial review limited to matters of interpretation; accepts compulsory ICJ jurisdiction, with reservations
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; has not accepted compulsory ICJ jurisdiction
Bulgaria civil law and criminal law based on Roman law; accepts compulsory ICJ jurisdiction with reservations
Burkina Faso based on French civil law system and customary law; has not accepted compulsory ICJ jurisdiction
Burma based on English common law; 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; accepts compulsory ICJ jurisdiction with reservations
Cameroon based on French civil law system, with common law influence; accepts 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 based on the legal system of Portugal; has not accepted compulsory ICJ jurisdiction
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 - in June 2005, Chile completed overhaul of its criminal justice system to a new, US-style adversarial system
China based on civil law system; derived from Soviet and continental civil code legal principles; legislature retains power to interpret statutes; constitution ambiguous on judicial review of legislation; has not accepted compulsory ICJ jurisdiction
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 into law in 2004 and is gradually being implemented; judicial review of executive and legislative acts
Comoros French and Islamic law in a new consolidated code
Congo, Democratic Republic of the a new constitution was adopted by referendum 18 December 2005; accepts compulsory ICJ jurisdiction, with reservations
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; accepts compulsory ICJ jurisdiction, with reservations
Croatia based on Austro-Hungarian law system with Communist law influences; has not accepted compulsory ICJ jurisdiction
Cuba based on Spanish civil law and influenced by American legal concepts, with large elements of Communist legal theory; has not accepted compulsory ICJ jurisdiction
Cyprus based on English common law, with civil law modifications; accepts compulsory ICJ jurisdiction, with reservations
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 Sovereign Base Area Administration has its own court system to deal with civil and criminal matters; laws applicable to the Cypriot population are, as far as possible, the same as the laws of the Republic of Cyprus
Djibouti based on French civil law system, traditional practices, and Islamic law; accepts ICJ jurisdiction, with reservations
Dominica based on English common law
Dominican Republic based on French civil codes; Criminal Procedures Code modified in 2004 to include important elements of an accusatory system; accepts compulsory ICJ jurisdiction
Ecuador based on civil law system; has not accepted compulsory ICJ jurisdiction
Egypt based on Islamic and civil law (particularly 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
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; government also issues unilateral proclamations setting laws and policies; also relies on customary and post-independence-enacted laws and, for civil cases involving Muslims, Islamic law; does not accept compulsory ICJ jurisdiction
Estonia based on civil law system; accepts compulsory ICJ jurisdiction with reservations
Ethiopia based on civil law; currently transitional mix of national and regional courts; has not accepted compulsory ICJ jurisdiction
European Union comparable to the legal systems of member states; first supranational law system
Falkland Islands (Islas Malvinas) English common law
Faroe Islands the laws of Denmark, where applicable, apply
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; has not accepted compulsory ICJ jurisdiction
French Polynesia the laws of France, where applicable, apply
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, Islamic law, and customary law; accepts compulsory ICJ jurisdiction with reservations
Georgia based on civil law system; accepts compulsory ICJ jurisdiction
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 the laws of the UK, where applicable, apply
Greece based on codified Roman law; judiciary divided into civil, criminal, and administrative courts; accepts compulsory ICJ jurisdiction with reservations
Greenland the laws of Denmark, where applicable, apply
Grenada based on English common law
Guam modeled on US; US federal laws apply
Guatemala civil law system; judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
Guernsey the laws of the UK, where applicable, apply; justice is administered by the Royal Court
Guinea based on French civil law system, customary law, and decree; accepts compulsory ICJ jurisdiction with reservations
Guinea-Bissau based on French civil law; accepts compulsory ICJ jurisdiction
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 based German-Austrian legal system; accepts compulsory ICJ jurisdiction with reservations
Iceland civil law system based on Danish law; has not accepted compulsory ICJ jurisdiction
India based on English common law; judicial review of legislative acts; accepts compulsory ICJ jurisdiction with reservations; separate personal law codes apply to Muslims, Christians, and Hindus
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 based on Sharia law system; has not accepted compulsory ICJ jurisdiction
Iraq based on European civil and Islamic law under the framework outlined in the Iraqi Constitution; has not accepted compulsory ICJ jurisdiction
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
Isle of Man the laws of the UK, where applicable, apply and Manx statutes
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 German 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 the laws of the UK, where applicable, apply and local statutes; 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
Kazakhstan based on Islamic law and Roman law; has not accepted compulsory ICJ jurisdiction
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 Prussian 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; has not accepted compulsory ICJ jurisdiction
Kuwait civil law system with Islamic law significant in personal matters; has not accepted compulsory ICJ jurisdiction
Kyrgyzstan based on French and Russian laws; has not accepted compulsory ICJ jurisdiction
Laos based on traditional customs, French legal norms and procedures, and socialist practice; has not accepted compulsory ICJ jurisdiction
Latvia based on civil law system with traces of Socialist legal traditions and practices; has not accepted compulsory ICJ jurisdiction
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; accepts compulsory ICJ jurisdiction with reservations
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; accepts compulsory ICJ jurisdiction with reservations
Libya based on Italian and French civil law systems 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 based on civil law system; accepts compulsory ICJ jurisdiction with reservations
Lithuania based on civil law system; legislative acts can be appealed to the constitutional court; has not accepted compulsory ICJ jurisdiction
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; has not accepted compulsory ICJ jurisdiction
Madagascar based on French civil law system and traditional Malagasy law; accepts compulsory ICJ jurisdiction with reservations
Malawi based on English common law and customary law; judicial review of legislative acts in the Supreme Court of Appeal; accepts compulsory ICJ jurisdiction with reservations
Malaysia based on English common law; judicial review of legislative acts in the Supreme Court at request of supreme head of the federation; Islamic law is applied to Muslims in matters of family law and religion; 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; has not accepted compulsory ICJ jurisdiction
Malta based on English common law and Roman civil law; accepts compulsory ICJ jurisdiction with reservations
Marshall Islands based on adapted Trust Territory laws, acts of the legislature, municipal, common, and customary laws
Mauritania a combination of Islamic law and French civil law; has not accepted compulsory ICJ jurisdiction
Mauritius based on French civil law system with elements of English common law in certain areas; accepts compulsory ICJ jurisdiction with reservations
Mayotte the laws of France, where applicable, apply
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; accepts many UN and Organization for Security and Cooperation in Europe (OSCE) documents; has not accepted compulsory ICJ jurisdiction
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
Montenegro based on civil law system; has not accepted compulsory ICJ jurisdiction
Montserrat English common law and statutory law
Morocco based on Islamic law and French and Spanish civil law systems; judicial review of legislative acts in Constitutional Chamber of Supreme Court; has not accepted compulsory ICJ jurisdiction
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; accepts compulsory ICJ jurisdiction with reservations
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 based on 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 based on French civil law; the 1988 Matignon Accords grant substantial autonomy to the islands
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; accepts compulsory ICJ jurisdiction
Niger based on French civil law system and customary law; has not accepted compulsory ICJ jurisdiction
Nigeria based on English common law, Islamic law (in 12 northern states), and traditional law; accepts compulsory ICJ jurisdiction with reservations
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; has not accepted compulsory ICJ jurisdiction
Paraguay based on Argentine codes, Roman law, and French codes; judicial review of legislative acts in Supreme Court of Justice; accepts compulsory ICJ jurisdiction
Peru based on civil law system; accepts compulsory ICJ jurisdiction with reservations
Philippines based on Spanish and Anglo-American law; accepts compulsory ICJ jurisdiction with reservations
Pitcairn Islands local island by-laws
Poland based on a 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; accepts compulsory ICJ jurisdiction with reservations
Portugal based on 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 based on Islamic and civil law codes; discretionary system of law controlled by the amir, although civil codes are being implemented; Islamic law dominates family and personal matters; has not accepted compulsory ICJ jurisdiction
Romania based on civil law system; has not accepted compulsory ICJ jurisdiction
Russia based on civil law system; judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
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 Barthelemy the laws of France, where applicable, apply
Saint Helena English common law and statutes, supplemented by local statutes
Saint Kitts and Nevis based on English common law
Saint Lucia based on English common law
Saint Martin the laws of France, where applicable, apply
Saint Pierre and Miquelon the laws of France, where applicable, apply
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 Shari'a 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; accepts compulsory ICJ jurisdiction with reservations
Serbia based on civil law system; has not accepted compulsory ICJ jurisdiction
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; accepts compulsory ICJ jurisdiction with reservations; 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; has not accepted compulsory ICJ jurisdiction
Solomon Islands English common law, which is widely disregarded
Somalia no national system; a mixture of English common law, Italian law, Islamic Shari'a, and Somali customary law; accepts compulsory ICJ jurisdiction with reservations
South Africa based on Roman-Dutch law and English common law
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; accepts compulsory ICJ jurisdiction with reservations
Sri Lanka a highly complex mixture of English common law, Roman-Dutch, Kandyan, and Jaffna Tamil 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; however, the CPA establishes some protections for non-Muslims in Khartoum; some separate religious courts; accepts compulsory ICJ jurisdiction with reservations; the southern legal system is still developing under the CPA following the civil war; Islamic law will not apply to the southern states
Suriname based on Dutch legal system incorporating French penal theory; accepts compulsory ICJ jurisdiction with reservations
Svalbard the laws of Norway, where applicable, apply
Swaziland based on South African Roman-Dutch law in statutory courts and Swazi traditional law and custom in traditional courts; accepts compulsory ICJ jurisdiction with reservations
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 a combination of French and Ottoman civil law; Islamic law is used in the family court system; has not accepted compulsory ICJ jurisdiction
Taiwan based on civil law system; has not accepted compulsory ICJ jurisdiction
Tajikistan based on civil law system; no judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
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
Timor-Leste UN-drafted legal system based on Indonesian law remains in place but are to be replaced by civil and penal codes based on Portuguese law; these have passed but have not been promulgated; has not accepted compulsory ICJ jurisdiction
Togo French-based court system; accepts compulsory ICJ jurisdiction, with reservations
Tokelau New Zealand and local statutes
Tonga based on English common law
Trinidad and Tobago based on English common law; judicial review of legislative acts in the Supreme Court; has not accepted compulsory ICJ jurisdiction
Tunisia based on French civil law system and Islamic law; some judicial review of legislative acts in the Supreme Court in joint session; has not accepted compulsory ICJ jurisdiction
Turkey civil law system derived from various European continental legal systems; note - member of the European Court of Human Rights (ECHR), although Turkey claims limited derogations on the ratified European Convention on Human Rights; has not accepted compulsory ICJ jurisdiction
Turkmenistan based on civil law system and Islamic law; has not accepted compulsory ICJ jurisdiction
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; has not accepted compulsory ICJ jurisdiction
United Arab Emirates based on a dual system of Shari'a and civil courts; has not accepted compulsory ICJ jurisdiction
United Kingdom based on common law tradition with early Roman and modern continental influences; has nonbinding 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, which is still influenced by the Napoleonic Code) is based on English common law; judicial review of legislative acts; has not accepted compulsory ICJ jurisdiction
United States Pacific Island Wildlife Refuges the laws of the US, where applicable, apply
Uruguay based on Spanish civil law system; accepts compulsory ICJ jurisdiction
Uzbekistan based on civil law system; has not accepted compulsory ICJ jurisdiction
Vanuatu unified system being created from former dual French and British systems
Venezuela open, adversarial court system
Vietnam based on communist legal theory and French civil law system has not accepted compulsory ICJ jurisdiction
Virgin Islands based on US laws
Wake Island the laws of the US, where applicable, apply
Wallis and Futuna the laws of France, where applicable, apply
World all members of the UN are parties to the statute that established the International Court of Justice (ICJ) or World Court
Yemen based on Islamic law, Turkish law, English common law, and local tribal customary law; has not accepted compulsory ICJ jurisdiction
Zambia 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
Zimbabwe mixture of Roman-Dutch and English common law

This page was last updated on 17 January, 2008


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