Law Atlas

How The Law Decides
Sign In
Text size
100%
Theme
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
Mixed Systems
Filter Results26 entries
Connections

Includes

Source Major Legal Systems in the World TodayRene David and John E.C. Brierley

South African law is classified in comparative law as a mixed system combining Roman-Dutch civil law, English common law and indigenous customary law, the same classification S v Makwanyane and Another itself already carries.

Source Constitutional Court of South Africa (Britannica)

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

Source Major Legal Systems in the World TodayRene David and John E.C. Brierley

Family classification carried over from this entity's own recorded SubLabel (Mixed and Hybrid Legal Systems), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Mixed and Hybrid Legal Systems), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Mixed and Hybrid Legal Systems), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Mixed and Hybrid Legal Systems), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Mixed and Hybrid Legal Systems), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Mixed and Hybrid Legal Systems), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Mixed and Hybrid Legal Systems), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Mixed and Hybrid Legal Systems), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Mixed and Hybrid Legal Systems), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Mixed and Hybrid Legal Systems), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Mixed and Hybrid Legal Systems), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Mixed and Hybrid Legal Systems), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Mixed and Hybrid Legal Systems), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Mixed and Hybrid Legal Systems), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Mixed and Hybrid Legal Systems), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Mixed and Hybrid Legal Systems), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Mixed and Hybrid Legal Systems), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Mixed and Hybrid Legal Systems), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Mixed and Hybrid Legal Systems), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Mixed and Hybrid Legal Systems), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Mixed and Hybrid Legal Systems), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

Family classification carried over from this entity's own recorded SubLabel (Mixed and Hybrid Legal Systems), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

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).

Mecelle, Codes

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

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)

Family classification carried over from this entity's own recorded SubLabel (Mixed and Hybrid Legal Systems), assigned under the section-legal-systems structure wave (ruling 761) using the CIA World Factbook / JuriGlobe comparative-law family classification (system.Atlas.DataBrief, law). This edge materializes that existing classification as a connective fact; it is not a new independent research finding.

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)

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

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).

Source Major Legal Systems in the World TodayRene David and John E.C. Brierley

Legal Family Of

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)
Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)
Source List of national legal systems (Wikipedia)
Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)
Source List of national legal systems (Wikipedia)
Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)
Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Source List of national legal systems (Wikipedia)

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

Entity-backed identity for the legal family value this legal-system already carries as an enum fact, resolved to a legal-system entity by an explicit value-to-entity map (phase 3 bucket conversion, docs\design_entity_backed_browse_buckets_20260928.md). The enum fact itself stays on the entity unchanged.

In the Other Atlases
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
Comments (0)
No comments yet. Be the first to share a thought.
Reader Challenges (0)
No disputes yet. Spotted an error or a better source? Open the first one.