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Legal System

Civil Law

Also Known As Continental Law

Civil Law Family

Civil law is a legal system in which comprehensive written codes, rather than judicial precedent, are the primary source of law, with courts interpreting and applying the code rather than making binding law of their own. The tradition traces its intellectual roots to ancient Roman law, especially its sixth century compilation under the Byzantine Emperor Justinian I, the Corpus Juris Civilis, rediscovered and studied intensively in medieval European universities from the eleventh century onward, and took its modern codified form in the national civil codes enacted across Europe from the early nineteenth century, most influentially the Napoleonic Code of 1804. It is the most widespread legal system in the world today by number of jurisdictions, covering most of continental Europe, Latin America, and large parts of Africa and Asia.

Facts

Disputed

Origin Year

1804 2

1804, the enactment of the Napoleonic Code, is taken here as the origin of the modern codified civil law tradition, since it was the model most widely adopted or adapted by other nations. The tradition intellectual roots are far older, tracing to Roman law and particularly to Justinian own sixth century Corpus Juris Civilis, so which date counts as origin depends on whether the Roman legal inheritance or its modern codified form is meant.

Example Jurisdictions

France, Germany, Italy, Spain, most of continental Europe, Latin America, and large parts of Africa and Asia. 2

Primary Source of Law

Comprehensive written codes and statutes, with case law playing a secondary, interpretive role. 3

Classification

Legal Family

Civil Law 1

Civil Law

16 entries

Era

Country or Jurisdiction

Legal Status

Authored By

Group Tree

Constitution of Austria

Constitution of Belgium

Constitution of Greece

Constitution of Hungary

Constitution of Italy

Constitution of Liechtenstein

Constitution of Moldova

Constitution of Monaco

Constitution of Poland

Constitution of Portugal

Constitution of Romania

Constitution of San Marino

Constitution of the Netherlands

Constitution of Ukraine

Federal Constitution of Switzerland

Spanish Constitution of 1978

Connections

Showing the first 400 of 501 connections.

Includes

Karl von Lilienthal

Source World Legal Systems, alphabetical index (JuriGlobe)

Source Central Intelligence Agency: France, The World Factbook (factbook.json archive copy)

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of Argentina

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of Bulgaria

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of Colombia

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of Kazakhstan

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of Lithuania

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of Luxembourg

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of Mongolia

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of Paraguay

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of Portugal

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of Slovakia

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of Slovenia

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of South Korea

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of Switzerland

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of Thailand

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of the Czech Republic

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of the Netherlands

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Law of the People's Republic of China

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Legal-system family: Civil Law Family, following the CIA World Factbook and JuriGlobe comparative-law family classification.

Showing 201 to 250 of 392 in Includes, page 5 of 8.

Held Differently

Court of Justice of the European Union (CJEU)

Why this is disputed. The CJEU is a supranational court whose case law draws heavily on continental civil law method and whose member states are mostly civil law jurisdictions, but EU law itself is often described by comparative scholars as a distinct legal order rather than a member of any single one of the five traditions; the civil law classification here reflects the Court's dominant working method, not a claim that EU law is simply continental civil law.

Source The Oxford Handbook of Comparative LawMathias Reimann and Reinhard Zimmermann, editors

Civil law systems generally provide analogous judicial protection against arbitrary detention through differently named procedures rather than through habeas corpus as such.

Source Habeas Corpus (Legal Information Institute, Cornell Law School)

Judicial Review

Civil law jurisdictions generally exercise constitutional review through a single dedicated constitutional court rather than diffusing it across the ordinary judiciary as the United States does, a different account of the same underlying power rather than a rejection of it.

Civil law systems reach a broadly comparable result through the distinct concepts of dol (intent) and culpa (fault) rather than through mens rea as such, a different account of criminal culpability rather than a rejection of it.

Source Mens Rea (Wikipedia)

M'Naghten Rules

Civil law systems generally excuse a mentally disordered defendant through their own non-responsibility provisions (for example Article 122-1 of the French Penal Code), a differently framed doctrine reaching a broadly similar result rather than the M'Naghten test itself.

Source M'Naghten Rules (Wikipedia)

Civil law systems generally express the rule of law through the Rechtsstaat tradition and codified principles of legality rather than through the common law rule of law as such.

In the Other Atlases

Found In

Also in Geography Atlas: where this subject is found.

Also in Geography Atlas: where this subject is found.

Also in Geography Atlas: where this subject is found.

Also in Geography Atlas: where this subject is found.

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

Also in Geography Atlas: where this subject is found.

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

Also in Geography Atlas: where this subject is found.

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

Also in Geography Atlas: where this subject is found.

Also in Geography Atlas: where this subject is found.

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

Sources

1. Wikipedia: Civil law

Civil law (legal system), or continental law, a legal system originating in continental Europe and based on Roman lawView the Source

2. Major Legal Systems in the World Today

Rene David and John E.C. Brierley, Stevens and Sons, 1985

Example Jurisdictions: France, Germany, Italy, Spain, most of continental Europe, Latin America, and large parts of Africa and Asia.
Origin Year: 1804

3. An Introduction to Comparative Law

Konrad Zweigert and Hein Koetz; English translation by Tony Weir, Clarendon Press, Oxford, 1998

Primary Source of Law: Comprehensive written codes and statutes, with case law playing a secondary, interpretive role.

The Oxford Handbook of Comparative Law

Mathias Reimann and Reinhard Zimmermann, editors, Oxford University Press, 2006

Includes: Court of Justice of the European Union (CJEU)
Includes: Administrative Law
Includes: Proportionality

Encyclopaedia Britannica

Encyclopaedia Britannica, Inc.

Includes: Hugo Grotius
Includes: Andres Bello
Includes: Dalmacio Velez Sarsfield

View the Source

Personal Information Protection Law of the People's Republic of China (Wikipedia)

Includes: Personal Information Protection Law (PIPL)View the Source

Abuse of Law (Max Planck Encyclopedia of European Private Law)

Includes: Abuse of RightsView the Source

Rechtsstaat (Wikipedia)

Includes: RechtsstaatView the Source

REACH, Regulation (EC) No 1907/2006 (EUR-Lex)

Publications Office of the European UnionIncludes: REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals)View the Source

Montesquieu (Wikipedia)

WikipediaIncludes: Separation of Powers, Lead paragraph - in-legal-system civil-law

Quote, Includes: Separation of Powers, Lead paragraph - in-legal-system civil-law

a French jurist, historian, and political philosopher

View the Source

Law of France (Wikipedia)

WikipediaIncludes: French Legal SystemView the Source

M'Naghten Rules (Wikipedia)

Includes: M'Naghten RulesView the Source

Stare Decisis (Legal Information Institute, Cornell Law School)

Includes: Precedent (Stare Decisis)

Mens Rea (Wikipedia)

WikipediaIncludes: Mens ReaView the Source

Habeas Corpus (Legal Information Institute, Cornell Law School)

Includes: Habeas CorpusView the Source

Civil Code of the Empire of Ethiopia, 1960 (WIPO Lex)

Includes: Civil Code of Ethiopia (1960)

Contempt of court (Wikipedia)

Includes: Contempt of court, Article text

Quote, Includes: Contempt of court, Article text

Judges in common law systems usually have more extensive power to declare someone in contempt than judges in civil law systems.

View the Source

Contract (Wikipedia)

WikipediaIncludes: Contract Law, Article text

Quote, Includes: Contract Law, Article text

contract law is exercised and governed either under common law jurisdictions, civil law jurisdictions, or mixed-law jurisdictions that combine elements of both common and civil law.

View the Source

Central Intelligence Agency: Kosovo, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Constitutional Court of Kosovo, Government - Legal system

Quote, Includes: Constitutional Court of Kosovo, Government - Legal system

civil law system

View the Source

Tort (Wikipedia)

WikipediaIncludes: Tort Law, Lead section

Quote, Includes: Tort Law, Lead section

While tort law in civil law jurisdictions largely derives from Roman law, common law jurisdictions derive their tort law from customary English tort law.

View the Source

Central Intelligence Agency: France, The World Factbook (factbook.json archive copy)

Central Intelligence Agency

Includes: Michel Debré, Government, Legal system
civil law; review of administrative but not legislative acts
Includes: Philippe Bas, Government: Legal system
civil law; review of administrative but not legislative acts
Includes: Alain Juppe, Government: Legal system
civil law; review of administrative but not legislative acts
Includes: Laurent Fabius, Government: Legal system
civil law; review of administrative but not legislative acts

View the Source

JuriGlobe World Legal Systems: Alphabetical Index of the Political Entities and Corresponding Legal Systems

JuriGlobe World Legal Systems

Includes: Antonie Iorgovan, Romania entry
ROMANIA Civil law
Includes: Jovan Hadžić, Serbia entry
SERBIA Civil law

Legal system of Macau (Wikipedia)

Legal Family Of: Legal system of Macau, Lead
Macau law is broadly based on Portuguese law, and therefore part of the civil law tradition of continental European legal systems.
Includes: Legal system of Macau, Lead
Macau law is broadly based on Portuguese law, and therefore part of the civil law tradition of continental European legal systems.

View the Source

World Legal Systems, alphabetical index (JuriGlobe)

JuriGlobe World Legal Systems Research Group, University of Ottawa

Includes: Shirin Ebadi, Index of states, Iran
Muslim/Civil law
Includes: Adhémar Esmein, Alphabetical list, France
FRANCE ( FR ) Civil law
Includes: Carlo Francesco Gabba, Alphabetical list, Italy
ITALY Civil law
Includes: Contardo Ferrini, Alphabetical list, Italy
ITALY Civil law
Includes: Emerico Amari, Alphabetical list, Italy
ITALY Civil law
Includes: Édouard René de Laboulaye, Alphabetical list, France
FRANCE ( FR ) Civil law
Includes: Ernst Immanuel Bekker, Alphabetical list, Germany
GERMANY Civil law
Includes: Joseph Louis Elzéar Ortolan, Alphabetical list, France
FRANCE ( FR ) Civil law
Includes: Andreas Frederik Krieger, Alphabetical list, Denmark
DENMARK ( DK ) Civil law
Includes: Otto Mejer, Alphabetical list, Germany
GERMANY Civil law
Includes: Eugène Ortolan, Alphabetical list, France
FRANCE ( FR ) Civil law
Includes: Carlo Biotti, Index of states, Italy
Civil law
Includes: Ahmet Necdet Sezer, Index of states, Turkey
Civil law
Includes: Simone Veil, Index of states, France
Civil law
Includes: Giuliano Amato, Index of states, Italy
Civil law
Includes: Giuseppe Conte, Index of states, Italy
Civil law
Includes: Pridi Banomyong, Index of states, Thailand
Civil law
Includes: Sergio Mattarella, Index of states, Italy
Civil law
Includes: Rasmus Carl Stæger, Alphabetical list, Denmark
DENMARK ( DK ) Civil law
Includes: Christian Pløyen, Alphabetical list, Denmark
DENMARK ( DK ) Civil law
Includes: Peter Franz Ignaz Deiters, Alphabetical list, Germany
GERMANY Civil law
Includes: Carlo Bon Compagni di Mombello, Alphabetical list, Italy
ITALY Civil law
Includes: Andreas Aagesen, Alphabetical list, Denmark
DENMARK ( DK ) Civil law
Includes: Otto von Oehlschläger, Alphabetical list, Germany
GERMANY Civil law
Includes: Adolphe de Chambrun, Alphabetical list, France
FRANCE ( FR ) Civil law
Includes: Sebastiaan Matheus Sigismund de Ranitz, Alphabetical list, Netherlands
NETHERLANDS ( NL ) Civil law
Includes: Jules Liégeois, Alphabetical list, France
FRANCE ( FR ) Civil law
Includes: Jacob Friedrich Behrend, Alphabetical list, Germany
GERMANY Civil law
Includes: Franz August Schenk von Stauffenberg, Alphabetical list, Germany
GERMANY Civil law
Includes: Anthony Modderman, Alphabetical list, Netherlands
NETHERLANDS ( NL ) Civil law
Includes: Rudolf Arnold Nieberding, Alphabetical list, Germany
GERMANY Civil law
Includes: Willem Anthony Engelbrecht, Alphabetical list, Netherlands
NETHERLANDS ( NL ) Civil law
Includes: Charles de Franqueville, Alphabetical list, France
FRANCE ( FR ) Civil law
Includes: Hendrik Jacob Hamaker, Alphabetical list, Netherlands
NETHERLANDS ( NL ) Civil law
Includes: Georges Hilaire Bousquet, Alphabetical list, France
FRANCE ( FR ) Civil law
Includes: Luigi Miraglia, Alphabetical list, Italy
ITALY Civil law
Includes: Geoffroi Jacques Flach, Alphabetical list, France
FRANCE ( FR ) Civil law
Includes: Ugo Sorani, Alphabetical list, Italy
ITALY Civil law
Includes: Camillo Finocchiaro Aprile, Alphabetical list, Italy
ITALY Civil law
Includes: Émile Garçon, Alphabetical list, France
FRANCE ( FR ) Civil law
Includes: Paul von Krause, Alphabetical list, Germany
GERMANY Civil law
Includes: Carlo Fadda, Alphabetical list, Italy
ITALY Civil law
Includes: Karl von Lilienthal, Alphabetical list, Germany
GERMANY Civil law
Includes: Biagio Brugi, Alphabetical list, Italy
ITALY Civil law
Includes: Reinhard Frank, Alphabetical list, Germany
GERMANY Civil law
Includes: Wolfgang Heine, Alphabetical list, Germany
GERMANY Civil law
Includes: Hugo Haase, Alphabetical list, Germany
GERMANY Civil law
Includes: Carlo Schanzer, Alphabetical list, Italy
ITALY Civil law
Includes: Eugène Wilhelm, Alphabetical list, France
FRANCE ( FR ) Civil law
Includes: Friedrich Ackermann, Alphabetical list, Germany
GERMANY Civil law
Includes: Marko Bošnjak (judge), Alphabetical index, slovenia
SLOVENIA Civil law

View the Source

Ludovico Barassi (Wikipedia)

Includes: Ludovico Barassi, Lead, civil law

Quote, Includes: Ludovico Barassi, Lead, civil law

one of Italy's leading authorities on civil law

View the Source

Victor D'Hondt (Wikipedia)

Includes: Victor D'Hondt, Lead

Quote, Includes: Victor D'Hondt, Lead

jurist of civil law at Ghent University

View the Source

Guido Panciroli (Wikipedia)

Includes: Guido Panciroli, Biography, civil law chair

Quote, Includes: Guido Panciroli, Biography, civil law chair

teaching in civil law and receiving a very healthy salary of 1000 scudi

View the Source

Alberto Bolognetti (Wikipedia)

Includes: Alberto Bolognetti, Biography

Quote, Includes: Alberto Bolognetti, Biography

He was a professor of civil law at the studium of Bologna

View the Source

Francesco Alciati (Wikipedia)

Includes: Francesco Alciati, Biography

Quote, Includes: Francesco Alciati, Biography

was appointed professor of civil law at the university of Pavia

View the Source

Antoine Dadin de Hauteserre (Wikipedia)

Includes: Antoine Dadin de Hauteserre, Biography

Quote, Includes: Antoine Dadin de Hauteserre, Biography

distinguished himself in civil and canon law

View the Source

List of national legal systems (Wikipedia)

Legal Family Of: Legal System of Cuba, Section: Civil law
Cuba
Legal Family Of: Legal System of Vietnam, Section: Civil law
Vietnam
Legal Family Of: Law of Spain, Section: Civil law
Spain
Legal Family Of: Law of Ethiopia, Section: Civil law
Ethiopia
Legal Family Of: Law of Greece, Section: Civil law
Greece
Legal Family Of: Law of Colombia, Section: Civil law
Colombia
Legal Family Of: Law of Iceland, Section: Civil law
Iceland
Legal Family Of: Law of Austria, Section: Civil law
Austria
Legal Family Of: Law of Estonia, Section: Civil law
Estonia
Legal Family Of: Law of Bolivia, Section: Civil law
Bolivia
Legal Family Of: Law of Ecuador, Section: Civil law
Ecuador
Legal Family Of: Law of Paraguay, Section: Civil law
Paraguay
Legal Family Of: Law of Lebanon, Section: Civil law
Lebanon
Legal Family Of: Law of Mongolia, Section: Civil law
Mongolia
Legal Family Of: Law of Slovenia, Section: Civil law
Slovenia
Legal Family Of: Law of Andorra, Section: Civil law
Andorra
Legal Family Of: Law of Timor-Leste, Section: Civil law
Timor-Leste
Legal Family Of: Law of Armenia, Section: Civil law
Armenia
Legal Family Of: Law of the Dominican Republic, Section: Civil law
Dominican Republic
Legal Family Of: Law of Angola, Section: Civil law
Angola
Legal Family Of: Law of Belarus, Section: Civil law
Belarus
Legal Family Of: Law of Benin, Section: Civil law
Benin
Legal Family Of: Law of Bosnia and Herzegovina, Section: Civil law
Bosnia and Herzegovina
Legal Family Of: Law of Burkina Faso, Section: Civil law
Burkina Faso
Legal Family Of: Law of Cabo Verde, Section: Civil law
Cape Verde
Legal Family Of: Law of the Central African Republic, Section: Civil law
Central African Republic
Legal Family Of: Law of Chad, Section: Civil law
Chad
Legal Family Of: Law of the Republic of the Congo, Section: Civil law
Republic of the Congo
Legal Family Of: Law of Costa Rica, Section: Civil law
Costa Rica
Legal Family Of: Law of Cote d'Ivoire, Section: Civil law
Ivory Coast
Legal Family Of: Law of Gabon, Section: Civil law
Gabon
Legal Family Of: Law of Georgia (country), Section: Civil law
Georgia
Legal Family Of: Law of Guatemala, Section: Civil law
Guatemala
Legal Family Of: Law of Guinea-Bissau, Section: Civil law
Guinea-Bissau
Legal Family Of: Law of Haiti, Section: Civil law
Haiti
Legal Family Of: Law of Vietnam, Section: Civil law
Vietnam
Legal Family Of: Law of North Macedonia, Section: Civil law
North Macedonia
Legal Family Of: Law of Mozambique, Section: Civil law
Mozambique
Legal Family Of: Law of Uzbekistan, Section: Civil law
Uzbekistan
Legal Family Of: Law of Montenegro, Section: Civil law
Montenegro
Legal Family Of: Law of Syria, National legal systems table, Syria
Based on Napoleonic civil law.

View the Source

General State Laws for the Prussian States (Wikipedia)

Includes: General State Laws for the Prussian States, Wikipedia lead sentence

Quote, Includes: General State Laws for the Prussian States, Wikipedia lead sentence

The code had over 17,000 articles, and covered fields of civil law, penal law, family law, public law, administrative law etc.

View the Source

Usufruct (Wikipedia)

Includes: Usufruct, Wikipedia lead sentence

Quote, Includes: Usufruct, Wikipedia lead sentence

fructus) is a limited real right (or in rem right) found in civil law and mixed jurisdictions that unites the two property interests of usus and fr

View the Source

Hypothec (Wikipedia)

Includes: Hypothec, Wikipedia lead sentence

Quote, Includes: Hypothec, Wikipedia lead sentence

hypothēkē), sometimes tacit hypothec, is a term used in civil law systems (e.g. the law of most of Continental Europe) to refer to a registered

View the Source

Synallagmatic contract (Wikipedia)

Includes: Synallagmatic contract, Wikipedia lead sentence

Quote, Includes: Synallagmatic contract, Wikipedia lead sentence

In civil law systems, a synallagmatic contract is a contract in which each party to the contract is bound to provide something to the other party

View the Source

Legal good (Wikipedia)

Includes: Legal good, Wikipedia lead sentence

Quote, Includes: Legal good, Wikipedia lead sentence

In the civil law tradition, a legal good is an interest or right that the legal system protects

View the Source

Obrogation (Wikipedia)

Includes: Obrogation, Wikipedia lead sentence

Quote, Includes: Obrogation, Wikipedia lead sentence

In civil law, obrogation (Latin: obrogat from obrogare) is the modification or repeal of a law in whole or in part by issuing a new law

View the Source

Patrimony of affectation (Wikipedia)

Includes: Patrimony of affectation, Wikipedia lead sentence

Quote, Includes: Patrimony of affectation, Wikipedia lead sentence

In certain civil law jurisdictions (e.g., France, Quebec, Mexico, etc.), the patrimoine d'affectation is property, assets, or a legal estate that can

View the Source

Servitude in civil law (Wikipedia)

Includes: Servitude in civil law, Introduction

Quote, Includes: Servitude in civil law, Introduction

At civil law, ownership (dominium) (e.g.

View the Source

Matrimonial regime (Wikipedia)

Includes: Matrimonial regime, Introduction

Quote, Includes: Matrimonial regime, Introduction

Matrimonial regimes are applied either by operation of law or by way of prenuptial agreement in civil-law countries, and depend on the lex domicilii of the spouses at the time of or immediately following the wedding.

View the Source

Usucaption (Wikipedia)

Includes: Usucaption, Lead paragraph

Quote, Includes: Usucaption, Lead paragraph

Usucaption (Latin: usucapio), also known as acquisitive prescription, is a concept found in civil law systems and has its origin in the Roman law of property.

View the Source

Inquisitorial system (Wikipedia)

Includes: Inquisitorial system, Lead paragraph

Quote, Includes: Inquisitorial system, Lead paragraph

Inquisitorial systems are used primarily in countries with civil legal systems, such as France and Italy, or legal systems based on Islamic law like Saudi Arabia, rather than in common law systems.

View the Source

Jurisprudence constante (Wikipedia)

Includes: Jurisprudence constante, Lead paragraph

Quote, Includes: Jurisprudence constante, Lead paragraph

This doctrine is recognized in most civil law jurisdictions as well as in certain mixed jurisdictions such as Louisiana.

View the Source

Saisine (Wikipedia)

Includes: Saisine, Lead paragraph

Quote, Includes: Saisine, Lead paragraph

This principle is notably prevalent in civil law jurisdictions, such as France, Germany and Quebec.

View the Source

Contravention (Wikipedia)

Includes: Contravention, Lead paragraph

Quote, Includes: Contravention, Lead paragraph

In civil law, a contravention is a lesser offense, similar to an infraction or civil penalty in common law countries.

View the Source

Legitime (Wikipedia)

Includes: Legitime, Lead paragraph

Quote, Includes: Legitime, Lead paragraph

In civil law and Roman law, the legitime (legitima portio), also known as a forced share or legal right share, of a decedent's estate is that portion of the estate from which they cannot disinherit their children, or their parents, without sufficient legal cause.

View the Source

Actio libera in causa (Wikipedia)

Includes: Actio libera in causa, Lead

Quote, Includes: Actio libera in causa, Lead

Actio libera in causa (frequently abbreviated as a.l.i.c., Latin for "action free in its cause") is a law principle in a typical Western law system (both common law and civil law).

View the Source

Legal origins theory (Wikipedia)

Includes: Legal origins theory, Lead

Quote, Includes: Legal origins theory, Lead

The legal origins theory claims that the two main legal traditions or origins, civil law and common law, crucially shape lawmaking and dispute adjudication and have not been reformed after the initial exogenous transplantation by Europeans.

View the Source

Central Intelligence Agency: Honduras, The World Factbook (factbook.json archive copy)

Central Intelligence Agency

Includes: Constitution of Honduras, Government: Legal system
civil law system
Includes: Wagner Vallecillo, Government: Legal system
civil law system
Includes: Rebeca Raquel Obando, Government: Legal system
civil law system
Includes: Supreme Court of Honduras, Government: Legal system
civil law system

View the Source

Central Intelligence Agency: El Salvador, The World Factbook (factbook.json archive copy)

Central Intelligence Agency

Includes: Constitution of El Salvador, Government: Legal system
civil law system with minor common law influence
Includes: Henry Alexander Mejia, Government: Legal system
civil law system with minor common law influence; Supreme Court reviews legislative acts
Includes: Supreme Court of Justice of El Salvador, Government, legal system
civil law system with minor common law influence;

View the Source

Central Intelligence Agency: Nicaragua, The World Factbook (factbook.json archive copy)

Central Intelligence Agency

Includes: Constitution of Nicaragua, Government: Legal system
civil law system
Includes: Supreme Court of Justice of Nicaragua, Government: Legal system
civil law system
Includes: Alba Luz Ramos, Government: Legal system
civil law system; Supreme Court may review administrative acts
Includes: Ana Julia Guido Ochoa, Government: Legal system
civil law system; Supreme Court may review administrative acts

View the Source

Central Intelligence Agency: Suriname, The World Factbook (factbook.json archive copy)

Central Intelligence Agency

Includes: Constitution of Suriname, Government: Legal system
civil law system influenced by Dutch civil law
Includes: Iwan Rasoelbaks, Government: Legal system
civil law system influenced by Dutch civil law
Includes: High Court of Justice of Suriname, Government, legal system, legal system of Suriname
civil law system influenced by Dutch civil law

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Central Intelligence Agency: Senegal, The World Factbook (factbook.json archive copy)

Central Intelligence Agency

Includes: Constitution of Senegal, Government: Legal system
civil law system based on French law
Includes: Youssoupha Ndiaye, Government: Legal system
civil law system based on French law; Constitutional Council reviews legislative acts
Includes: Supreme Court of Senegal, Government, legal system
civil law system based on French law; Constitutional Council reviews legislative acts
Includes: Constitutional Council of Senegal, Government, legal system
civil law system based on French law; Constitutional Council reviews legislative acts

View the Source

Central Intelligence Agency: Madagascar, The World Factbook (factbook.json archive copy)

Central Intelligence Agency

Includes: Constitution of Madagascar, Government: Legal system
civil law system based on the old French civil code and customary law in matters of marriage, family, and obligation
Includes: Claudette Sophia Ramanankavana, Government: Legal system
civil law system based on the old French civil code and customary law in matters of marriage, family, and obligation
Includes: Supreme Court of Madagascar, Government, legal system
civil law system based on the old French civil code and customary law in matters of marriage, family, and obligation

View the Source

Central Intelligence Agency: Liechtenstein, The World Factbook (factbook.json archive copy)

Central Intelligence Agency

Includes: Constitution of Liechtenstein, Government: Legal system
civil law system influenced by Swiss, Austrian, and German law
Includes: Supreme Court of Liechtenstein, Government, legal system
civil law system influenced by Swiss, Austrian, and German law

View the Source

Central Intelligence Agency: Turkmenistan, The World Factbook (factbook.json archive copy)

Central Intelligence Agency

Includes: Constitution of Turkmenistan, Government: Legal system
civil law system with Islamic (sharia) law influences
Includes: Supreme Court of Turkmenistan, Government, legal system, legal system of Turkmenistan
civil law system with Islamic (sharia) law influences

View the Source

Central Intelligence Agency: Tajikistan, The World Factbook (factbook.json archive copy)

Central Intelligence Agency

Includes: Constitution of Tajikistan, Government: Legal system
civil law system
Includes: Rustam Mirzozoda, Government: Legal system
civil law system
Includes: Supreme Court of Tajikistan, Government, legal system
civil law system

View the Source

Central Intelligence Agency: Kyrgyzstan, The World Factbook (factbook.json archive copy)

Central Intelligence Agency

Includes: Constitution of Kyrgyzstan, Government: Legal system
civil law system that includes features of French civil law and Russian Federation laws
Includes: Mederbek Satyev, Government: Legal system
civil law system that includes features of French civil law and Russian Federation laws
Includes: Supreme Court of Kyrgyzstan, Government, legal system
civil law system that includes features of French civil law and Russian Federation laws
Includes: Constitutional Court of Kyrgyzstan, Government, legal system
civil law system that includes features of French civil law and Russian Federation laws

View the Source

Central Intelligence Agency: Guinea, The World Factbook (factbook.json archive copy)

Central Intelligence Agency

Includes: Constitution of Guinea, Government: Legal system
civil law system based on the French model
Includes: Fatoumata Yarie Soumah, Government: Legal system
civil law system based on the French model
Includes: Supreme Court of Guinea, Government, legal system
civil law system based on the French model

View the Source

Central Intelligence Agency: Mali, The World Factbook (factbook.json archive copy)

Central Intelligence Agency

Includes: Constitution of Mali, Government: Legal system
civil law system based on the French civil law model and influenced by customary law
Includes: Manassa Danioko, Government: Legal system
civil law system based on the French civil law model and influenced by customary law; Constitutional Court reviews legislative acts
Includes: Constitutional Court of Mali, Government, legal system
civil law system based on the French civil law model and influenced by customary law;
Includes: Supreme Court of Mali, Government, legal system
civil law system based on the French civil law model and influenced by customary law;

View the Source

Central Intelligence Agency: Moldova, The World Factbook (factbook.json archive copy)

Central Intelligence Agency

Includes: Constitution of Moldova, Government: Legal system
civil law system with Germanic law influences
Includes: Domnica Manole, Government: Legal system
civil law system with Germanic law influences; Constitutional Court reviews legislative acts
Includes: Constitutional Court of Moldova, Government: Legal system
civil law system with Germanic law influences

View the Source

Central Intelligence Agency: Monaco, The World Factbook (factbook.json archive copy)

Central Intelligence Agency

Includes: Constitution of Monaco, Government: Legal system
civil law system influenced by French legal tradition
Includes: Supreme Court of Monaco, Government, legal system
civil law system influenced by French legal tradition

View the Source

Central Intelligence Agency: San Marino, The World Factbook (factbook.json archive copy)

Central Intelligence Agency

Includes: Constitution of San Marino, Government: Legal system
civil law system with Italian civil law influences
Includes: Council of Twelve of San Marino, Government, legal system
civil law system with Italian civil law influences

View the Source

Central Intelligence Agency: Taiwan, The World Factbook (factbook.json archive copy)

Central Intelligence Agency

Includes: Constitution of the Republic of China, Government: Legal system
civil law system
Includes: Supreme Court of the Republic of China (Taiwan), Government: Legal system
civil law system
Includes: Judicial Yuan, Government: Legal system
civil law system
Includes: Hsu Tzong-li, Government: Legal system
civil law system

View the Source

Central Intelligence Agency: Kazakhstan, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyLegal Family Of: Law of Kazakhstan, Government: Legal system

Quote, Legal Family Of: Law of Kazakhstan, Government: Legal system

civil law system influenced by Roman-Germanic law and by the theory and practice of the Russian Federation

View the Source

Non ultra petita (Wikipedia)

Includes: Non ultra petita, Lead

Quote, Includes: Non ultra petita, Lead

The principle is a traditional basis of the rules of procedure governing civil and administrative litigation in continental legal systems, and in public international law.

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Central Intelligence Agency: Serbia, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Miroljub Tomic, Government: Legal system

Quote, Includes: Miroljub Tomic, Government: Legal system

civil law system

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Central Intelligence Agency: Bhutan, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Norbu Tshering, Government: Legal system

Quote, Includes: Norbu Tshering, Government: Legal system

civil law based on Buddhist religious law

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Central Intelligence Agency: Brazil, The World Factbook (factbook.json archive copy)

Central Intelligence Agency

Includes: André Mendonça, Government: Legal system
civil law
Includes: Carmen Lucia, Government: Legal system
civil law

View the Source

Central Intelligence Agency: Portugal, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Joao Cura Mariano, Government: Legal system

Quote, Includes: Joao Cura Mariano, Government: Legal system

civil law system; Constitutional Court reviews legislative acts

View the Source

Central Intelligence Agency: Democratic Republic of the Congo, The World Factbook (factbook.json archive copy)

Central Intelligence Agency

Includes: Marcel Lihau, Government: Legal system
civil law system primarily based on Belgian law, but also customary and tribal law
Includes: Nicolas Bayona Ba Meya, Government: Legal system
civil law system primarily based on Belgian law, but also customary and tribal law
Includes: Elie-Leon Ndomba Kabeya, Government: Legal system
civil law system primarily based on Belgian law, but also customary and tribal law
Includes: Court of Cassation of the Democratic Republic of the Congo, Government, legal system
civil law system primarily based on Belgian law
Includes: Supreme Court of Justice of Zaire, Government, legal system
civil law system primarily based on Belgian law

View the Source

Central Intelligence Agency: Turkey, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Furuzan Ikincioullari, Government: Legal system

Quote, Includes: Furuzan Ikincioullari, Government: Legal system

civil law system based on various European systems, notably the Swiss civil code

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Central Intelligence Agency: Estonia, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Villu Kove, Government: Legal system

Quote, Includes: Villu Kove, Government: Legal system

civil law system

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Central Intelligence Agency: Germany, The World Factbook (factbook.json archive copy)

Central Intelligence Agency

Includes: Udo Steiner, Government: Legal system
civil law system
Includes: Astrid Wallrabenstein, Government: Legal system
civil law system
Includes: Dieter Grimm, Government: Legal system
civil law system
Includes: Holger Wöckel, Government: Legal system
civil law system
Includes: Henning Radtke, Government: Legal system
civil law system
Includes: Martin Eifert, Government: Legal system
civil law system
Includes: Miriam Meßling, Government: Legal system
civil law system
Includes: Rhona Fetzer, Government: Legal system
civil law system
Includes: Heinrich Amadeus Wolff, Government: Legal system
civil law system
Includes: Sigrid Emmenegger, Government: Legal system
civil law system
Includes: Yvonne Ott, Government: Legal system
civil law system
Includes: Günter Spinner, Government: Legal system
civil law system
Includes: Ines Härtel, Government: Legal system
civil law system
Includes: Thomas Offenloch, Government: Legal system
civil law system

View the Source

Central Intelligence Agency: Luxembourg, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Thierry Hoscheit, Government: Legal system

Quote, Includes: Thierry Hoscheit, Government: Legal system

civil law system

View the Source

Central Intelligence Agency: Vietnam, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Nguyen Van Quang, Government: Legal system

Quote, Includes: Nguyen Van Quang, Government: Legal system

civil law system with European influences

View the Source

Central Intelligence Agency: Haiti, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Jean Joseph Lebrun, Government: Legal system

Quote, Includes: Jean Joseph Lebrun, Government: Legal system

civil law system strongly influenced by Napoleonic Code

View the Source

Central Intelligence Agency: The Dominican, The World Factbook (factbook.json archive copy)

Central Intelligence Agency

Includes: Luis Henry Molina Pena, Government: Legal system
civil law system based on the French civil code; Criminal Procedures Code modified in 2004 to include important elements of an accusatory system
Includes: Mariano German Mejía, Government: Legal system
civil law system based on the French civil code; Criminal Procedures Code modified in 2004 to include important elements of an accusatory system

View the Source

Central Intelligence Agency: Peru, The World Factbook (factbook.json archive copy)

Central Intelligence Agency

Includes: Delia Revoredo, Government: Legal system
civil law system
Includes: Pedro Hernández Chávez, Government: Legal system
civil law system

View the Source

Central Intelligence Agency: Latvia, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Aigars Strupiss, Government: Legal system

Quote, Includes: Aigars Strupiss, Government: Legal system

civil law system with traces of socialist legal traditions and practices

View the Source

Central Intelligence Agency: Armenia, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Arman Dilanyan, Government: Legal system

Quote, Includes: Arman Dilanyan, Government: Legal system

civil law system

View the Source

Central Intelligence Agency: Colombia, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Manuel José Cepeda Espinosa, Government: Legal system

Quote, Includes: Manuel José Cepeda Espinosa, Government: Legal system

civil law system influenced by the Spanish and French civil codes

View the Source

Central Intelligence Agency: Paraguay, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Luis Maria Benitez Riera, Government: Legal system

Quote, Includes: Luis Maria Benitez Riera, Government: Legal system

civil law system with influences from Argentine, Spanish, Roman, and French civil law models; Supreme Court of Justice reviews legislative acts

View the Source

Central Intelligence Agency: China, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Ma Xiwu, Government: Legal system

Quote, Includes: Ma Xiwu, Government: Legal system

civil law influenced by Soviet and continental European civil law systems; legislature retains power to interpret statutes

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Central Intelligence Agency: Bolivia, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Paola Prudencio Candia, Government: Legal system

Quote, Includes: Paola Prudencio Candia, Government: Legal system

civil law system with influences from Roman, Spanish, canon (religious), French, and ethnic groups' pre-colonial law

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Central Intelligence Agency: Slovenia, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Rok Čeferin, Government: Legal system

Quote, Includes: Rok Čeferin, Government: Legal system

civil law system

View the Source

Central Intelligence Agency: Cote d'Ivoire, The World Factbook (factbook.json archive copy)

Central Intelligence Agency

Includes: Chantal Camara, Government: Legal system
civil law system based on the French civil code; Constitutional Chamber of the Supreme Court reviews legislation
Includes: Joachim Yua Koffi, Government: Legal system
civil law system based on the French civil code; Constitutional Chamber of the Supreme Court reviews legislation
Includes: Constitutional Council of Cote d'Ivoire, Government, legal system
civil law system based on the French civil code;

View the Source

Central Intelligence Agency: Benin, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Cossi Dorothe Sossa, Government: Legal system

Quote, Includes: Cossi Dorothe Sossa, Government: Legal system

civil law system modeled largely on the French system and some customary law

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Central Intelligence Agency: Slovakia, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Ivan Fiacan, Government: Legal system

Quote, Includes: Ivan Fiacan, Government: Legal system

civil law system based on Austro-Hungarian codes

View the Source

Central Intelligence Agency: Finland, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Tatu Leppanen, Government: Legal system

Quote, Includes: Tatu Leppanen, Government: Legal system

civil law system based on the Swedish model

View the Source

Central Intelligence Agency: Chile, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Maria Pia Silva Gallinato, Government: Legal system

Quote, Includes: Maria Pia Silva Gallinato, Government: Legal system

civil law system influenced by several Western European civil legal systems; Constitutional Tribunal reviews legislative acts

View the Source

Central Intelligence Agency: Mauritius, The World Factbook (factbook.json archive copy)

Central Intelligence Agency

Includes: Ariranga Pillay, Government: Legal system
civil system based on French civil law with some elements of English common law
Includes: Supreme Court of Mauritius, Government: Legal system
civil system based on French civil law with some elements of English common law

View the Source

Central Intelligence Agency: Poland, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Bogdan Swieczkowski, Government: Legal system

Quote, Includes: Bogdan Swieczkowski, Government: Legal system

civil law system; judicial review of legislative, administrative, and other governmental acts; constitutional law rulings of the Constitutional Tribunal are final

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Central Intelligence Agency: Guatemala, The World Factbook (factbook.json archive copy)

Central Intelligence Agency

Includes: Annabella Morfín, Government: Legal system
civil law system; judicial review of legislative acts
Includes: Oscar Cruz Oliva, Government: Legal system
civil law system; judicial review of legislative acts
Includes: Nester Vasquez, Government: Legal system
civil law system; judicial review of legislative acts

View the Source

Central Intelligence Agency: Cuba, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Oscar Manuel Silvera Martinez, Government: Legal system

Quote, Includes: Oscar Manuel Silvera Martinez, Government: Legal system

civil law system based on Spanish civil code

View the Source

Central Intelligence Agency: Cambodia, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Chiv Keng, Government: Legal system

Quote, Includes: Chiv Keng, Government: Legal system

civil law system (influenced by the UN Transitional Authority in Cambodia), customary law, Communist legal theory, and common law

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Central Intelligence Agency: Lithuania, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Danguole Subliene, Government: Legal system

Quote, Includes: Danguole Subliene, Government: Legal system

civil law system; legislative acts can be appealed to the Constitutional Court

View the Source

Central Intelligence Agency: Costa Rica, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Orlando Aguirre Gómez, Government: Legal system

Quote, Includes: Orlando Aguirre Gómez, Government: Legal system

civil law system based on Spanish civil code; Supreme Court reviews legislative acts

View the Source

Civil law (legal system) (Wikipedia)

WikipediaIn Group: Roman Law and Ius Commune Foundations, Introduction, sentence 1

Quote, In Group: Roman Law and Ius Commune Foundations, Introduction, sentence 1

Civil law is a legal system rooted in the Roman Empire and was comprehensively codified and disseminated starting in the 19th century, most notably with France's Napoleonic Code (1804) and Germany's Bürgerliches Gesetzbuch (1900).

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Central Intelligence Agency: Djibouti, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Supreme Court of Djibouti, Government, legal system

Quote, Includes: Supreme Court of Djibouti, 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

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Central Intelligence Agency: Mauritania, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Supreme Court of Mauritania, Government, legal system

Quote, Includes: Supreme Court of Mauritania, Government, legal system

mixed system of Islamic and French civil law

View the Source

Central Intelligence Agency: Tunisia, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Court of Cassation of Tunisia, Government, legal system, legal system of Tunisia

Quote, Includes: Court of Cassation of Tunisia, Government, legal system, legal system of Tunisia

mixed system of civil law, based on the French civil code and Islamic (sharia) law

View the Source

Central Intelligence Agency: Equatorial Guinea, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Supreme Court of Justice of Equatorial Guinea, Government, legal system, legal system of Equatorial Guinea

Quote, Includes: Supreme Court of Justice of Equatorial Guinea, Government, legal system, legal system of Equatorial Guinea

mixed system of civil and customary law

View the Source

Central Intelligence Agency: Eritrea, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: High Court of Eritrea, Government, legal system, legal system of Eritrea

Quote, Includes: High Court of Eritrea, Government, legal system, legal system of Eritrea

mixed system of civil, customary, and Islamic religious law

View the Source

Central Intelligence Agency: Seychelles, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Court of Appeal of Seychelles, Government, legal system, legal system of Seychelles

Quote, Includes: Court of Appeal of Seychelles, Government, legal system, legal system of Seychelles

mixed system of English common law, French civil law, and customary law

View the Source

Central Intelligence Agency: Comoros, The World Factbook (factbook.json archive copy)

Central Intelligence AgencyIncludes: Supreme Court of the Comoros, Government, legal system, legal system of Comoros

Quote, Includes: Supreme Court of the Comoros, Government, legal system, legal system of Comoros

mixed legal system of Islamic religious law, the French civil code of 1975, and customary law

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World Factbook archive, Georgia profile

Includes: Supreme Court of Georgia, Government, legal system, legal system of Georgia

Quote, Includes: Supreme Court of Georgia, Government, legal system, legal system of Georgia

civil law system

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Open Questions (1 open question)

Is Socialist Law a Distinct Legal Family, or a Variant of the Civil Law Tradition?

Comparativists have never fully settled this. Rene David's influential classification treated socialist law (the historical Soviet system and its export to Eastern Europe, China and elsewhere) as a family of its own, defined by the subordination of law to Communist Party policy and state ownership, even though its courts, codes and legal vocabulary were built on a civil-law base. Zweigert and Kotz, working from a different comparative method, are more skeptical that this political fact by itself creates a distinct legal FAMILY rather than a civil-law variant under unusual political conditions, and post-1989 practice complicates the question further: China's law today keeps socialist characteristics in name while its commercial and procedural codes converge heavily with mainstream civil law.

What would resolve this A comparative-law consensus classification would need to specify which feature is doing the definitional work, legal FORM (codes, courts, procedure, which stayed civil-law in shape) or POLITICAL FUNCTION (subordination to party policy, which did not), since the two point to different answers; a jurisdiction-by-jurisdiction study tracking how far post-1989 codes have converged with ordinary civil law would also narrow the question for any single country.

Konrad Zweigert and Hein Koetz; English translation by Tony Weir, An Introduction to Comparative Law

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