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Legal System

Mixed Systems

Also Known As Hybrid Legal Systems
Mixed and Hybrid Legal Systems

Mixed systems combine elements of common law, civil law, religious law or customary law within a single jurisdiction, generally as the historical result of one legal tradition being layered atop another through conquest, colonization or migration rather than one clean tradition being adopted wholesale. Well documented examples include Louisiana and Quebec, whose private law remains civil law inherited from French rule within otherwise common law nations; South Africa, which blends Roman-Dutch civil law, English common law and customary law; Scotland, which blends civilian and common law influences within the United Kingdom; and the Philippines and Israel, each of which layers civil law, common law and, in domains such as family law, religious law.

Facts
Example Jurisdictions
Louisiana and Quebec; South Africa; Scotland; the Philippines; Israel. 1
Primary Source of Law
A blend of codified statutes, judicial precedent, and, in some jurisdictions, customary or religious law, in proportions that vary by jurisdiction. 2
Connections

Includes

Law of Malaysia, Legal Systems

Legal-system family: Mixed and Hybrid Legal Systems, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of Morocco, Legal Systems

Legal-system family: Mixed and Hybrid Legal Systems, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of Nepal, Legal Systems

Legal-system family: Mixed and Hybrid Legal Systems, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of Nigeria, Legal Systems

Legal-system family: Mixed and Hybrid Legal Systems, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of Oman, Legal Systems

Legal-system family: Mixed and Hybrid Legal Systems, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of Pakistan, Legal Systems

Legal-system family: Mixed and Hybrid Legal Systems, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of Qatar, Legal Systems

Legal-system family: Mixed and Hybrid Legal Systems, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of Sri Lanka, Legal Systems

Legal-system family: Mixed and Hybrid Legal Systems, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of Sudan, Legal Systems

Legal-system family: Mixed and Hybrid Legal Systems, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of Syria, Legal Systems

Legal-system family: Mixed and Hybrid Legal Systems, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of the Philippines, Legal Systems

Legal-system family: Mixed and Hybrid Legal Systems, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of the United Arab Emirates, Legal Systems

Legal-system family: Mixed and Hybrid Legal Systems, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of Yemen, Legal Systems

Legal-system family: Mixed and Hybrid Legal Systems, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Louisiana Law, Legal Systems

Named as one of the mixed-systems family, among its own worked examples (private law inherited from French rule within an otherwise common law nation).

Mamoru Nakamura, Jurists
Source Central Intelligence Agency: Palau, The World Factbook (factbook.json archive copy)
Mecelle, Codes
Michael Corbett, Jurists
Source Central Intelligence Agency: South Africa, The World Factbook (factbook.json archive copy)
Minister of Home Affairs v Fourie, Landmark Cases

Matches the existing S v Makwanyane precedent for South African Constitutional Court rulings on this atlas.

Mohammad Ghazo, Jurists
Source Central Intelligence Agency: Jordan, The World Factbook (factbook.json archive copy)
Mumba Malila, Jurists
Source Central Intelligence Agency: Zambia, The World Factbook (factbook.json archive copy)
Mundhir Ibrahim Hussein, Jurists
Source Central Intelligence Agency: Iraq, The World Factbook (factbook.json archive copy)
Oldiais Ngiraikelau, Jurists
Source Central Intelligence Agency: Palau, The World Factbook (factbook.json archive copy)
Ottoman Land Code of 1858, Codes

The code is described in the source as an original Ottoman creation, neither purely European nor entirely Islamic, founded on traditional practice with categories drawn from Islamic law.

Source Ottoman Land Code of 1858 (Wikipedia)
Pierre Rabie, Jurists
Source Central Intelligence Agency: South Africa, The World Factbook (factbook.json archive copy)
Quebec Law, Legal Systems

Legal-system family: Mixed and Hybrid Legal Systems, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Rizine Mzikamanda, Jurists
Source Central Intelligence Agency: Malawi, The World Factbook (factbook.json archive copy)
S v Makwanyane and Another, Landmark Cases

South African law is classified in comparative law as a mixed system combining Roman-Dutch civil law, English common law and indigenous customary law.

Source S v Makwanyane and Another, Constitutional Court of South Africa Judgment (Refworld)
Scots Law, Legal Systems

Named as one of the mixed-systems family, among its own worked examples (civilian and common law influences within the United Kingdom).

South African Law, Legal Systems

Named as one of the mixed-systems family, among its own worked examples (Roman-Dutch civil law, English common law and customary law blended in one jurisdiction).

Supreme Court of Appeal of Malawi, Courts
Source Central Intelligence Agency: Malawi, The World Factbook (factbook.json archive copy)
Supreme Court of Brunei Darussalam, Courts
Source Central Intelligence Agency: Brunei, The World Factbook (factbook.json archive copy)
Supreme Court of India, Courts
Source Major Legal Systems in the World TodayRene David and John E.C. Brierley
Supreme Court of Palau, Courts
Source Central Intelligence Agency: Palau, The World Factbook (factbook.json archive copy)
Supreme Court of Sierra Leone, Courts
Source Central Intelligence Agency: Sierra Leone, The World Factbook (factbook.json archive copy)
Supreme Court of the Federated States of Micronesia, Courts
Source Central Intelligence Agency: Micronesia, Federated States of, The World Factbook (factbook.json archive copy)
Supreme Court of The Gambia, Courts
Source Central Intelligence Agency: The Gambia, The World Factbook (factbook.json archive copy)
Supreme Court of Zambia, Courts
Source Central Intelligence Agency: Zambia, The World Factbook (factbook.json archive copy)
Thar Htay, Jurists
Source Central Intelligence Agency: Burma, The World Factbook (factbook.json archive copy)
Umu Hawa Tejan-Jalloh, Jurists
Source Central Intelligence Agency: Sierra Leone, The World Factbook (factbook.json archive copy)
Vincent Lunabek, Jurists
Source Central Intelligence Agency: Vanuatu, The World Factbook (factbook.json archive copy)

Showing 51 to 90 of 90 in Includes, page 2 of 2.

Legal Family Of

Indian Legal System, Legal Systems
Israeli Law, Legal Systems
Law of Algeria, Legal Systems
Source List of national legal systems (Wikipedia)
Law of Bahrain, Legal Systems
Law of Bhutan, Legal Systems
Law of Botswana, Legal Systems
Source List of national legal systems (Wikipedia)
Law of Cameroon, Legal Systems
Source List of national legal systems (Wikipedia)
Law of Canada, Legal Systems
Law of Eswatini, Legal Systems
Source List of national legal systems (Wikipedia)
Law of Indonesia, Legal Systems
Law of Iraq, Legal Systems
Source Central Intelligence Agency: Iraq, The World Factbook (factbook.json archive copy)
Law of Jersey, Legal Systems
Law of Jordan, Legal Systems
Source List of national legal systems (Wikipedia)
Law of Kenya, Legal Systems
Source List of national legal systems (Wikipedia)
Law of Kuwait, Legal Systems
Source Central Intelligence Agency: Kuwait, The World Factbook (factbook.json archive copy)
Law of Lesotho, Legal Systems
Source List of national legal systems (Wikipedia)
Law of Malaysia, Legal Systems
Law of Malta, Legal Systems
Law of Morocco, Legal Systems
Source List of national legal systems (Wikipedia)
Law of Namibia, Legal Systems
Law of Nigeria, Legal Systems
Law of Oman, Legal Systems
Source List of national legal systems (Wikipedia)
Law of Qatar, Legal Systems
Source List of national legal systems (Wikipedia)
Law of Rwanda, Legal Systems
Source List of national legal systems (Wikipedia)
Law of Samoa, Legal Systems
Law of Somalia, Legal Systems
Source Central Intelligence Agency: Somalia, The World Factbook (factbook.json archive copy)
Law of Sri Lanka, Legal Systems
Law of Sudan, Legal Systems
Source Central Intelligence Agency: Sudan, The World Factbook (factbook.json archive copy)
Law of the Ottoman Empire, Legal Systems
Law of the Philippines, Legal Systems
Source List of national legal systems (Wikipedia)
Law of the United Arab Emirates, Legal Systems
Source List of national legal systems (Wikipedia)
Law of Tunisia, Legal Systems
Source Central Intelligence Agency: Tunisia, The World Factbook (factbook.json archive copy)
Law of Tuvalu, Legal Systems
Law of Vanuatu, Legal Systems
Law of Yemen, Legal Systems
Law of Zimbabwe, Legal Systems
Source List of national legal systems (Wikipedia)
Louisiana Law, Legal Systems
Old French law, Legal Systems
Scots Law, Legal Systems
South African Law, Legal Systems
Traditional Chinese Legal Tradition, Legal Systems
In the Other Atlases

Found In

Africa

Also in Geography Atlas: where this subject is found.

Asia

Also in Geography Atlas: where this subject is found.

Sources
1. Major Legal Systems in the World Today
Rene David and John E.C. Brierley, Stevens and Sons, 1985
2. An Introduction to Comparative Law
Konrad Zweigert and Hein Koetz; English translation by Tony Weir, Clarendon Press, Oxford, 1998
S v Makwanyane and Another, Constitutional Court of South Africa Judgment (Refworld)
Includes: S v Makwanyane and AnotherView the Source
Constitutional Court of South Africa (Britannica)
Includes: Constitutional Court of South Africa
Ottoman Land Code of 1858 (Wikipedia)
Includes: Ottoman Land Code of 1858
List of national legal systems (Wikipedia)
  • Legal Family Of: Law of the Philippines, Section: Civil law and common law
    Philippines
  • Legal Family Of: Law of Kenya, Section: Civil law and common law
    Kenya
  • Legal Family Of: Law of Jordan, Section: Civil law and sharia law
    Jordan
  • Legal Family Of: Law of Qatar, Section: Civil law and sharia law
    Qatar
  • Legal Family Of: Law of Morocco, Section: Civil law and sharia law
    Morocco
  • Legal Family Of: Law of Algeria, Section: Civil law and sharia law
    Algeria
  • Legal Family Of: Law of Oman, Section: Civil law and sharia law
    Oman
  • Legal Family Of: Law of the United Arab Emirates, Section: Civil law and sharia law
    United Arab Emirates
  • Legal Family Of: Law of Botswana, Section: Civil law and common law
    Botswana
  • Legal Family Of: Law of Cameroon, Section: Civil law and common law
    Cameroon
  • Legal Family Of: Law of Zimbabwe, Section: Civil law and common law
    Zimbabwe
  • Legal Family Of: Law of Lesotho, Section: Civil law and common law
    Lesotho
  • Legal Family Of: Law of Eswatini, Section: Civil law and common law
    Eswatini
  • Legal Family Of: Law of Rwanda, National legal systems table, Rwanda
    Mixture of Belgian civil law and English common law
View the Source
Central Intelligence Agency: Solomon Islands, The World Factbook (factbook.json archive copy)
Central Intelligence Agency
  • Includes: Constitution of Solomon Islands, Government: Legal system
    mixed system of English common law and customary law
  • Includes: Albert Palmer, Government: Legal system
    mixed system of English common law and customary law
  • Includes: John Muria, Government: Legal system
    mixed system of English common law and customary law
  • Includes: Court of Appeal of Solomon Islands, Government, legal system
    mixed system of English common law and customary law
View the Source
Central Intelligence Agency: Brunei, The World Factbook (factbook.json archive copy)
Central Intelligence Agency
  • Includes: Constitution of Brunei, Government: Legal system
    mixed legal system based on English common law and Islamic law
  • Includes: Hayati binti Haji Mohd Salleh, Government: Legal system
    mixed legal system based on English common law and Islamic law
  • Includes: Supreme Court of Brunei Darussalam, Government, legal system
    mixed legal system based on English common law and Islamic law
View the Source
Central Intelligence Agency: Zambia, The World Factbook (factbook.json archive copy)
Central Intelligence Agency
  • Includes: Constitution of Zambia, Government: Legal system
    mixed system of English common law and customary law
  • Includes: Supreme Court of Zambia, Government: Legal system
    mixed system of English common law and customary law
  • Includes: Irene Mambilima, Government: Legal system
    mixed system of English common law and customary law
  • Includes: Mumba Malila, Government: Legal system
    mixed system of English common law and customary law
View the Source
Central Intelligence Agency: Malawi, The World Factbook (factbook.json archive copy)
Central Intelligence Agency
  • Includes: Constitution of Malawi, Government: Legal system
    mixed system of English common law and customary law
  • Includes: Rizine Mzikamanda, Government: Legal system
    mixed system of English common law and customary law; Supreme Court of Appeal reviews legislative acts
  • Includes: Supreme Court of Appeal of Malawi, Government: Legal system
    mixed system of English common law and customary law
View the Source
Central Intelligence Agency: Mauritania, The World Factbook (factbook.json archive copy)
Central Intelligence Agency
  • Includes: Constitution of Mauritania, Government: Legal system
    mixed system of Islamic and French civil law
  • Includes: Ahmed Ould Sidi Ahmed, Government: Legal system
    mixed system of Islamic and French civil law
View the Source
Central Intelligence Agency: Sierra Leone, The World Factbook (factbook.json archive copy)
Central Intelligence Agency
  • Includes: Constitution of Sierra Leone, Government: Legal system
    mixed system of English common law and customary law
  • Includes: Umu Hawa Tejan-Jalloh, Government: Legal system
    mixed system of English common law and customary law
  • Includes: Supreme Court of Sierra Leone, Government: Legal system
    mixed system of English common law and customary law
View the Source
Central Intelligence Agency: Equatorial Guinea, The World Factbook (factbook.json archive copy)
Central Intelligence AgencyIncludes: Constitution of Equatorial Guinea, Government: Legal system
Quote, Includes: Constitution of Equatorial Guinea, Government: Legal system
mixed system of civil and customary law
View the Source
Central Intelligence Agency: The Gambia, The World Factbook (factbook.json archive copy)
Central Intelligence Agency
  • Includes: Constitution of the Gambia, Government: Legal system
    mixed system of English common law, Islamic law, and customary law
  • Includes: Supreme Court of The Gambia, Government, legal system
    mixed system of English common law, Islamic law, and customary law
View the Source
Central Intelligence Agency: Djibouti, The World Factbook (factbook.json archive copy)
Central Intelligence Agency
  • Includes: Constitution of Djibouti, Government: Legal system
    mixed system based primarily on the French civil code
  • Includes: Khadija Abeba, Government: Legal system
    mixed 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
View the Source
Central Intelligence Agency: Eritrea, The World Factbook (factbook.json archive copy)
Central Intelligence AgencyIncludes: Constitution of Eritrea, Government: Legal system
Quote, Includes: Constitution of Eritrea, Government: Legal system
mixed system of civil, customary, and Islamic religious law
View the Source
Central Intelligence Agency: Marshall Islands, The World Factbook (factbook.json archive copy)
Central Intelligence Agency
  • Includes: Constitution of the Marshall Islands, Government: Legal system
    mixed system of US and English common law, customary law, and local statutes
  • Includes: Daniel N. Cadra, Government: Legal system
    mixed system of US and English common law, customary law, and local statutes
View the Source
Central Intelligence Agency: Palau, The World Factbook (factbook.json archive copy)
Central Intelligence Agency
  • Includes: Constitution of Palau, Government: Legal system
    mixed system of civil, common, and customary law
  • Includes: Supreme Court of Palau, Government: Legal system
    mixed system of civil, common, and customary law
  • Includes: Mamoru Nakamura, Government: Legal system
    mixed system of civil, common, and customary law
  • Includes: Arthur Ngirakelsong, Government: Legal system
    mixed system of civil, common, and customary law
  • Includes: Oldiais Ngiraikelau, Government: Legal system
    mixed system of civil, common, and customary law
View the Source
Central Intelligence Agency: Comoros, The World Factbook (factbook.json archive copy)
Central Intelligence AgencyIncludes: Constitution of the Comoros, Government: Legal system
Quote, Includes: Constitution of the Comoros, Government: Legal system
mixed legal system of Islamic religious law, the French civil code of 1975, and customary law
View the Source
Central Intelligence Agency: Seychelles, The World Factbook (factbook.json archive copy)
Central Intelligence AgencyIncludes: Constitution of Seychelles, Government: Legal system
Quote, Includes: Constitution of Seychelles, Government: Legal system
mixed system of English common law, French civil law, and customary law
View the Source
Central Intelligence Agency: Iraq, The World Factbook (factbook.json archive copy)
Central Intelligence Agency
  • Legal Family Of: Law of Iraq, Government: Legal system
    mixed system of civil and Islamic law
  • Includes: Mundhir Ibrahim Hussein, Government: Legal system
    mixed system of civil and Islamic law
View the Source
Central Intelligence Agency: Kuwait, The World Factbook (factbook.json archive copy)
Central Intelligence Agency
  • Legal Family Of: Law of Kuwait, Government: Legal system
    mixed system consisting of English common law, French civil law, and Islamic sharia law
  • Includes: Adel Boursli, Government: Legal system
    mixed system consisting of English common law, French civil law, and Islamic sharia law
View the Source
Central Intelligence Agency: Tunisia, The World Factbook (factbook.json archive copy)
Central Intelligence AgencyLegal Family Of: Law of Tunisia, Government: Legal system
Quote, Legal Family Of: Law of Tunisia, Government: Legal system
mixed system of civil law, based on the French civil code and Islamic (sharia) law
View the Source
Central Intelligence Agency: Sudan, The World Factbook (factbook.json archive copy)
Central Intelligence AgencyLegal Family Of: Law of Sudan, Government: Legal system
Quote, Legal Family Of: Law of Sudan, Government: Legal system
mixed system of Islamic law and English common law
View the Source
Central Intelligence Agency: Somalia, The World Factbook (factbook.json archive copy)
Central Intelligence AgencyLegal Family Of: Law of Somalia, Government: Legal system
Quote, Legal Family Of: Law of Somalia, Government: Legal system
mixed system of civil law, Islamic (sharia) law, and customary law
View the Source
Central Intelligence Agency: Nauru, The World Factbook (factbook.json archive copy)
Central Intelligence AgencyIncludes: Janmai Jay Udit, Government: Legal system
Quote, Includes: Janmai Jay Udit, Government: Legal system
mixed system of common law based on the English model and customary law
View the Source
Central Intelligence Agency: Jordan, The World Factbook (factbook.json archive copy)
Central Intelligence AgencyIncludes: Mohammad Ghazo, Government: Legal system
Quote, Includes: Mohammad Ghazo, Government: Legal system
mixed system developed from Ottoman Empire codes (based on French law), British common law, and Islamic law
View the Source
Central Intelligence Agency: Burma, The World Factbook (factbook.json archive copy)
Central Intelligence AgencyIncludes: Thar Htay, Government: Legal system
Quote, Includes: Thar Htay, Government: Legal system
mixed legal system of English common law (as introduced in codifications designed for colonial India) and customary law
View the Source
Central Intelligence Agency: South Africa, The World Factbook (factbook.json archive copy)
Central Intelligence Agency
  • Includes: Pierre Rabie, Government: Legal system
    mixed system of Roman-Dutch civil law, English common law, and customary law
  • Includes: John Wessels, Government: Legal system
    mixed system of Roman-Dutch civil law, English common law, and customary law
  • Includes: Michael Corbett, Government: Legal system
    mixed system of Roman-Dutch civil law, English common law, and customary law
View the Source
Central Intelligence Agency: Micronesia, Federated States of, The World Factbook (factbook.json archive copy)
Central Intelligence Agency
  • Includes: Beauleen Carl-Worswick, Government: Legal system
    mixed system of common and customary law
  • Includes: Supreme Court of the Federated States of Micronesia, Government: Legal system
    mixed system of common and customary law
View the Source
Central Intelligence Agency: Vanuatu, The World Factbook (factbook.json archive copy)
Central Intelligence AgencyIncludes: Vincent Lunabek, Government: Legal system
Quote, Includes: Vincent Lunabek, Government: Legal system
mixed system of English common law, French law, and customary law
View the Source
CIA World Factbook (factbook.json archive): The World Factbook archive: Hong Kong
CIA World Factbook (factbook.json archive)Includes: Court of Final Appeal of Hong Kong, Government: Legal system
Quote, Includes: Court of Final Appeal of Hong Kong, Government: Legal system
mixed system of common law based on the English model and Chinese customary law (in matters of family and land tenure)
View the Source
CIA World Factbook (factbook.json archive): The World Factbook archive: Niger
CIA World Factbook (factbook.json archive)Includes: Constitutional Court of Niger, Government: Legal system
Quote, Includes: Constitutional Court of Niger, Government: Legal system
mixed system of civil law, based on French civil law, Islamic law, and customary law
View the Source
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