Common Law Countries 2025

Country
Common Law Status
Legal System
Additional Common Law Details
IndiaYesCommonCommon law system based on the English model; separate personal law codes apply to Muslims, Christians, and Hindus; judicial review of legislative acts.
United StatesYesCommonCommon law system at the federal level; state legal systems based on common law, except Louisiana, where state law is based on Napoleonic civil code; judicial review applies.
TanzaniaYesCommonEnglish common law; judicial review limited to matters of interpretation.
United KingdomYesCommonCommon law system; has non-binding judicial review of Acts of Parliament under the Human Rights Act of 1998.
CanadaYesCommonCommon law system except in Quebec, where civil law based on the French civil code prevails.
AustraliaYesCommonCommon law system based on the English model.
SingaporeYesCommonEnglish common law.
LiberiaYesMixedMixed legal system of common law (Anglo-American) and customary law.
IrelandYesCommonCommon law system based on the English model but substantially modified by customary law; judicial review of legislative acts by the Supreme Court.
New ZealandYesCommonCommon law system based on the English model, with special legislation and land courts for the Maori.
JamaicaYesCommonCommon law system based on the English model.
Trinidad and TobagoYesCommonEnglish common law; judicial review in the Supreme Court.
FijiYesCommonCommon law system based on the English model.
GuyanaYesCommonCommon law system based on the English model, with some Roman-Dutch civil law influence.
BelizeYesCommonEnglish common law.
BahamasYesCommonCommon law system based on the English model.
BarbadosYesCommonEnglish common law; no judicial review of legislative acts.
Saint LuciaYesCommonEnglish common law.
GuamYesCommonCommon law modeled on US system; US federal laws apply.
KiribatiYesCommonEnglish common law supplemented by customary law.
GrenadaYesCommonCommon law based on English model.
TongaYesCommonEnglish common law.
Saint Vincent and the GrenadinesYesCommonEnglish common law.
Antigua and BarbudaYesCommonCommon law based on the English model.
United States Virgin IslandsYesCommonUS common law.
Isle of ManYesCommonThe laws of the UK apply where applicable and include Manx statutes.
Cayman IslandsYesCommonEnglish common law and local statutes.
DominicaYesCommonCommon law based on the English model.
BermudaYesCommonEnglish common law.
Saint Kitts and NevisYesCommonEnglish common law.
GibraltarYesCommonThe laws of the UK, where applicable, apply.
British Virgin IslandsYesCommonEnglish common law.
AnguillaYesCommonCommon law based on the English model.
Cook IslandsYesCommonCommon law similar to New Zealand common law.
MontserratYesCommonEnglish common law.
Falkland IslandsYesCommonEnglish common law and local statutes.
TokelauYesCommonCommon law system of New Zealand.
NiueYesCommonEnglish common law.
PakistanPartialMixedCommon law system with Islamic law influence.
NigeriaPartialMixedMixed legal system of English common law, Islamic law (12 northern states), and traditional law.
BangladeshPartialMixedCommon law; statutory law enacted by the Parliament of Bangladesh is the primary legislation form. Bangladeshi law incorporates elements of English common law. Islamic law applies to Muslims in family and inheritance matters, with Hindu personal law applying to Hindus and Buddhists.
EgyptPartialMixedMixed legal system based on Napoleonic civil and penal law, Islamic religious law, and vestiges of colonial-era laws; judicial review of the constitutionality of laws by the Supreme Constitutional Court.
PhilippinesPartialMixedMixed legal system of civil, common, Islamic (sharia), and customary law.
ThailandPartialMixedCivil law system with common law influences.
South AfricaPartialMixedMixed legal system of Roman-Dutch civil law, English common law, and customary law.
KenyaPartialMixedMixed legal system of English common law, Islamic law, and customary law; judicial review in the new Supreme Court established by the new constitution.
MyanmarPartialMixedMixed legal system of English common law (as introduced in codifications designed for colonial India) and customary law.
South KoreaPartialMixedMixed legal system combining European civil law, Anglo-American law, and Chinese classical thought.
SudanPartialMixedMixed legal system of Islamic law and English common law; amended penal code in mid-July 2020.
UgandaPartialMixedMixed legal system of English common law and customary law.
IraqPartialMixedMixed legal system of civil and Islamic law.
YemenPartialMixedMixed legal system of Islamic (sharia) law, Napoleonic law, English common law, and customary law.
MoroccoPartialMixedMixed legal system of civil law (French) and Islamic (sharia) law; judicial review by the Constitutional Court.
MalaysiaPartialMixedMixed legal system of English common law, Islamic law (sharia), and customary law; judicial review in the Federal Court.
MozambiquePartialMixedMixed legal system of Portuguese civil law and customary law.
GhanaPartialMixedMixed system of English common law and customary law.
MadagascarPartialMixedCivil law system based on the old French civil code; customary law in marriage, family, and obligations.
CameroonPartialMixedMixed legal system of English common law, French civil law, and customary law.
NepalPartialMixedEnglish common law and Hindu legal concepts; new criminal and civil codes effective 17 August 2018.
NigerPartialMixedFollowing the 26 July 2023 military coup, the National Council for the Safeguard of the Homeland assumed control and rules by decree; formerly a mixed legal system of French civil law, Islamic law, and customary law.
SyriaPartialMixedMixed legal system of civil and Islamic (sharia) law (for family courts).
MaliPartialMixedCivil law system based on the French civil law model; influenced by customary law; judicial review in the Constitutional Court.
Sri LankaPartialMixedMixed legal system of Roman-Dutch civil law, English common law, Jaffna Tamil customary law, and Muslim personal law.
MalawiPartialMixedMixed legal system of English common law and customary law; judicial review of legislative acts in the Supreme Court of Appeal.
ZambiaPartialMixedMixed legal system of English common law and customary law.
ChadPartialMixedMixed legal system of civil and customary law.
SomaliaPartialMixedMixed legal system of civil law, Islamic (sharia) law, and customary law (referred to as Xeer).
ZimbabwePartialMixedMixed legal system of English common law, Roman-Dutch civil law, and customary law
RwandaPartialMixedMixed legal system of civil law (German and Belgian models) and customary law; judicial review in the Supreme Court.
BurundiPartialMixedMixed legal system of Belgian civil law and customary law.
TunisiaPartialMixedMixed legal system of civil law (French model) and Islamic (sharia) law; limited judicial review in the Supreme Court in joint session.
JordanPartialMixedMixed system developed from codes instituted by the Ottoman Empire (based on French law), British common law, and Islamic law
United Arab EmiratesPartialMixedMixed legal system of Islamic (sharia) law and civil law.
Papua New GuineaPartialMixedMixed legal system of English common law and customary law.
IsraelPartialMixedMixed legal system of English common law, British Mandate regulations, and Jewish, Christian, and Muslim religious laws.
Sierra LeonePartialMixedMixed legal system of English common law and customary law.
Hong KongPartialMixedMixed legal system of common law based on the English model and Chinese customary law (in matters of family and land tenure); PRC imposition of National Security Law incorporates elements of Chinese civil law.
Republic of the CongoPartialMixedMixed legal system of French civil law and customary law.
LebanonPartialMixedMixed legal system of civil law based on the French civil code, Ottoman legal tradition, and religious laws covering personal status for Jewish, Islamic, and Christian communities.
NorwayPartialMixedMixed legal system of civil, common, and customary law; Supreme Court can advise on legislative acts.
OmanPartialMixedMixed legal system of Anglo-Saxon law and Islamic law.
MauritaniaPartialMixedMixed legal system of Islamic and French civil law.
KuwaitPartialMixedMixed legal system consisting of English common law, French civil law, and Islamic sharia law.
EritreaPartialMixedMixed legal system of civil, customary, and Islamic religious law.
QatarPartialMixedMixed legal system of civil law and Islamic (sharia) law (in family and personal matters).
NamibiaPartialMixedMixed legal system of uncodified civil law (Roman-Dutch) and customary law.
GambiaPartialMixedMixed legal system of English common law, Islamic law, and customary law.
GabonPartialMixedMixed legal system of French civil law and customary law.
BotswanaPartialMixedMixed legal system of civil law influenced by the Roman-Dutch model and also customary and common law.
LesothoPartialMixedMixed legal system of English common law and Roman-Dutch law; judicial review of legislative acts in High Court and Court of Appeal.
Guinea-BissauPartialMixedMixed legal system of civil law incorporating Portuguese law, influenced by ECOWAS, UEMOA, African Francophone Public Law, and customary law.
Equatorial GuineaPartialMixedMixed system of civil and customary law.
BahrainPartialMixedMixed legal system of Islamic (sharia) law, English common law, Egyptian civil, criminal, and commercial codes, and customary law.
CyprusPartialMixedMixed legal system of English common law and civil law with European law supremacy.
MauritiusPartialMixedCivil legal system based on French civil law with elements of English common law.
EswatiniPartialMixedMixed legal system of civil, common, and customary law.
DjiboutiPartialMixedMixed legal 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.
ComorosPartialMixedMixed legal system of Islamic religious law, the French civil code of 1975, and customary law.
Solomon IslandsPartialMixedMixed legal system of English common law and customary law.
MaltaPartialMixedMixed legal system of English common law and civil law (Roman and Napoleonic civil codes); subject to EU law.
MaldivesPartialMixedIslamic (sharia) legal system with English common law influences, primarily in commercial matters.
BruneiPartialMixedMixed legal system based on English common law and Islamic law; in April 2019, the full sharia penal codes came into force, applying to Muslims and partly to non-Muslims in parallel with present common law codes.
VanuatuPartialMixedMixed legal system of English common law, French law, and customary law.
Sao Tome and PrincipePartialMixedMixed legal system of civil law (Portuguese model) and customary law.
SamoaPartialMixedMixed legal system of English common law and customary law; judicial review of legislative acts with respect to fundamental rights of the citizen.
SeychellesPartialMixedMixed legal system of English common law, French civil law, and customary law.
MicronesiaPartialMixedMixed legal system of common law and customary law.
JerseyPartialMixedThe laws of the UK apply where applicable; includes local statutes.
GuernseyPartialMixedCustomary legal system based on Norman customary law; includes elements of the French civil code and English common law.
Turks and Caicos IslandsPartialMixedMixed legal system of English common law and civil law.
American SamoaPartialMixedMixed legal system of US common law and customary law.
Sint MaartenPartialMixedDutch civil law system with some English common law influence.
Marshall IslandsPartialMixedMixed legal system of US and English common law, customary law, and local statutes.
PalauPartialMixedMixed legal system of civil, common, and customary law.
NauruPartialMixedMixed legal system of common law (English) and customary law.
TuvaluPartialMixedMixed legal system of English common law and local customary law
ChinaNoCivilCivil law influenced by Soviet and continental European civil law systems; legislature retains power to interpret statutes; in May 2020, the National People's Congress adopted the PRC Civil Code.
IndonesiaNoCivilCivil law system based on the Roman-Dutch model and influenced by customary law.
BrazilNoCivilCivil law; a new civil law code was enacted in 2002, replacing the 1916 code.
RussiaNoCivilCivil law system; judicial review of legislative acts.
EthiopiaNoCivilCivil law system
MexicoNoCivilCivil law system with US constitutional law influence; judicial review of legislative acts.
JapanNoCivilCivil law system based on the German model; reflects Anglo-American influence and Japanese traditions; judicial review of legislative acts in the Supreme Court.
DR CongoNoCivilCivil law system primarily based on Belgian law, but also customary and tribal law.
VietnamNoCivilCivil law system; the civil code of 2005 reflects a European-style civil law.
IranNoReligiousReligious legal system based on secular and Islamic law.
TurkeyNoCivilCivil law system based on various European legal systems, notably the Swiss civil code.
GermanyNoCivilCivil law system.
FranceNoCivilCivil law; review of administrative but not legislative acts.
ItalyNoCivilCivil law system; judicial review of legislation under certain conditions in the Constitutional Court.
ColombiaNoCivilCivil law system influenced by the Spanish and French civil codes.
SpainNoCivilCivil law system with regional variations.
AlgeriaNoMixedMixed legal system of French civil law and Islamic law; judicial review of legislative acts in an ad hoc Constitutional Council composed of various public officials, including several Supreme Court justices.
ArgentinaNoCivilCivil law system based on West European legal systems; in mid-2015, Argentina adopted a new civil code, replacing the old one in force since 1871.
AfghanistanNoReligiousThe Taliban is implementing its own interpretation of Islamic law, partially based on the Hanafi school of Islamic jurisprudence, enforcing strict punishments. Before the Taliban takeover, Afghanistan had a mixed legal system of civil, customary, and Islamic law.
AngolaNoCivilCivil legal system based on Portuguese civil law; no judicial review of legislation.
UkraineNoCivilCivil law system; judicial review of legislative acts.
PolandNoCivilCivil law system; judicial review of legislative, administrative, and other governmental acts; constitutional law rulings are final.
UzbekistanNoCivilCivil law system; criminal code reforms were part of a constitutional referendum passed in April 2023.
PeruNoCivilCivil law system.
Saudi ArabiaNoIslamicIslamic (sharia) legal system with some elements of Egyptian, French, and customary law; commercial disputes handled by special committees.
Ivory CoastNoCivilCivil law system based on the French civil code; judicial review of legislation held in the Constitutional Chamber of the Supreme Court.
VenezuelaNoCivilCivil law system based on the Spanish civil code.
North KoreaNoCivilCivil law system based on the Prussian model; system influenced by Japanese traditions and Communist legal theory.
Burkina FasoNoMixedCivil law based on the French model and customary law; in mid-2019, the National Assembly amended the penal code.
TaiwanNoCivilCivil law system.
KazakhstanNoCivilCivil law system influenced by Roman-Germanic law and by the theory and practice of the Russian Federation.
ChileNoCivilCivil law system influenced by several West European civil legal systems; judicial review of legislative acts by the Constitutional Tribunal.
SenegalNoCivilCivil law system based on French law; judicial review of legislative acts in the Constitutional Council.
RomaniaNoCivilCivil law system.
GuatemalaNoCivilCivil law system; judicial review of legislative acts.
NetherlandsNoCivilCivil law system based on the French system; constitution prohibits judicial review of acts of the States General.
EcuadorNoCivilCivil law based on the Chilean civil code with modifications; traditional law in indigenous communities.
CambodiaNoMixedCivil law system influenced by the UN Transitional Authority in Cambodia, customary law, Communist legal theory, and common law.
GuineaNoCivilCivil law system based on the French model.
BeninNoCivilCivil law system modeled largely on the French system and some customary law.
BoliviaNoCivilCivil law system with influences from Roman, Spanish, canon (religious), French, and indigenous law.
HaitiNoCivilCivil law system strongly influenced by Napoleonic Code.
BelgiumNoCivilCivil law system based on the French Civil Code; Belgian law continues to be modified in conformance with the legislative norms mandated by the European Union; judicial review of legislative acts.
Dominican RepublicNoCivilCivil law system based on the French civil code; Criminal Procedures Code modified in 2004 to include important elements of an accusatory system.
HondurasNoCivilCivil law system.
CubaNoCivilCivil law system based on the Spanish civil code.
TajikistanNoCivilCivil law system.
SwedenNoCivilCivil law system influenced by Roman-Germanic law and customary law.
Czech RepublicNoCivilNew civil code enacted in 2014, replacing the 1964 civil code, based on former Austro-Hungarian civil codes and socialist theory, reintroducing former Czech legal terminology.
PortugalNoCivilCivil law system; Constitutional Court review of legislative acts.
AzerbaijanNoCivilCivil law system.
GreeceNoCivilCivil legal system based on Roman law.
TogoNoCustomaryCustomary law system.
HungaryNoCivilCivil legal system influenced by the German model.
AustriaNoCivilCivil law system; judicial review of legislative acts by the Constitutional Court.
BelarusNoCivilCivil law system; nearly all major codes (civil, civil procedure, criminal, criminal procedure, family, and labor) were revised and came into force in 1999 and 2000.
SwitzerlandNoCivilCivil law system; judicial review of legislative acts, except for federal decrees of general obligatory character.
LaosNoCivilCivil law system similar in form to the French system.
TurkmenistanNoCivilCivil law system with Islamic (sharia) law influences.
LibyaNoMixedLegal system in flux, driven by state and non-state entities post-revolution.
KyrgyzstanNoCivilCivil law system, which includes features of French civil law and Russian Federation laws.
ParaguayNoCivilCivil law system with influences from Argentine, Spanish, Roman, and French models; judicial review of legislative acts in Supreme Court of Justice.
NicaraguaNoCivilCivil law system; Supreme Court may review administrative acts.
BulgariaNoCivilCivil law.
SerbiaNoCivilCivil law system.
El SalvadorNoCivilCivil law system with minor common law influence; judicial review of legislative acts in the Supreme Court.
DenmarkNoCivilCivil law; judicial review of legislative acts.
FinlandNoCivilCivil law system based on the Swedish model.
Central African RepublicNoCivilCivil law system based on the French model.
SlovakiaNoCivilCivil law system based on Austro-Hungarian codes; legal code modified to comply with OSCE obligations.
Costa RicaNoCivilCivil law system based on Spanish civil code; judicial review of legislative acts in the Supreme Court.
PanamaNoCivilCivil law system; judicial review of legislative acts in the Supreme Court of Justice.
CroatiaNoCivilCivil law system influenced by the legal heritage of Austria-Hungary; Croatian law was fully harmonized with the European Community acquis as of June 2010.
GeorgiaNoCivilCivil law system.
MongoliaNoCivilCivil law system influenced by Soviet and Romano-Germanic legal systems; constitution ambiguous on judicial review.
UruguayNoCivilCivil law system based on the Spanish civil code.
Puerto RicoNoCivilCivil law system based on the Spanish civil code within the framework of the US federal system.
Bosnia and HerzegovinaNoCivilCivil law system; Constitutional Court review of legislative acts.
MoldovaNoCivilCivil law system with Germanic law influences; legislative acts reviewed by the Constitutional Court.
ArmeniaNoCivilCivil law system.
LithuaniaNoCivilCivil law system; legislative acts can be appealed to the Constitutional Court.
AlbaniaNoCivilCivil law system except in the northern rural areas where customary law known as the "Code of Leke" is still present.
SloveniaNoCivilCivil law system.
LatviaNoCivilCivil law system with traces of socialist legal traditions and practices.
North MacedoniaNoCivilCivil law system; judicial review of legislative acts.
Timor-LesteNoCivilCivil law system based on the Portuguese model; replaced Indonesian codes with new penal and civil codes in 2009 and 2011.
EstoniaNoCivilCivil law system.
BhutanNoCivilCivil law based on Buddhist religious law.
MacauNoCivilCivil law system based on the Portuguese model.
LuxembourgNoCivilCivil law system.
SurinameNoCivilCivil law system influenced by Dutch civil law; new criminal code enacted in 2017.
MontenegroNoCivilCivil law system.
Cape VerdeNoCivilCivil law system of Portugal.
IcelandNoCivilCivil law system influenced by the Danish model.
New CaledoniaNoCivilCivil law system based on French civil law.
French PolynesiaNoCivilThe laws of France, where applicable, apply.
CuracaoNoCivilBased on Dutch civil law.
ArubaNoCivilCivil law system based on the Dutch civil code.
AndorraNoMixedMixed legal system of civil and customary law with the influence of canon (religious) law.
Faroe IslandsNoCivilThe laws of Denmark apply where applicable.
GreenlandNoMixedThe laws of Denmark apply where applicable, and Greenlandic law applies to other areas.
Northern Mariana IslandsNoMixedThe laws of the US apply, except for customs and some taxation aspects.
LiechtensteinNoCivilCivil law system influenced by Swiss, Austrian, and German law.
MonacoNoCivilCivil law system influenced by French legal tradition.
San MarinoNoCivilCivil law system with Italian civil law influences.
Saint MartinNoCivilFrench civil law.
Saint BarthelemyNoCivilFrench civil law.
Wallis and FutunaNoCivilFrench civil law.
Saint Pierre and MiquelonNoCivilFrench civil law.
Vatican CityNoReligiousReligious legal system based on canon (religious) law.