List of national legal systems

LIST OF NATIONAL LEGAL SYSTEMS

The contemporary national legal systems are generally based on one of four basic systems: civil law, common law, statutory law, religious law or combinations of these. However, the legal system of each country is shaped by its unique history and so incorporates individual variations.^[1] The science that studies law at the level of legal systems is called comparative law.
Both civil (also known as Roman) and common law systems can be considered the most widespread in the world: civil law because it is the most widespread by landmass and by population overall, and common law because it is employed by the greatest number of people compared to any single civil law system

Civil law

The source of law that is recognized as authoritative is codifications in a constitution or statute passed by legislature, to amend a code. While the concept of codification dates back to the Code of Hammurabi in Babylon ca. 1790 BC, civil law systems derive from the Roman Empire and, more particularly, the Corpus Juris Civilis issued by the Emperor Justinian ca. AD 529. This was an extensive reform of the law in the Byzantine Empire, bringing it together into codified documents. Civil law was also partly influenced by religious laws such as Canon law and Islamic law.^[5][6] Civil law today, in theory, is interpreted rather than developed or made by judges. Only legislative enactments (rather than legal precedents, as in common law) are considered legally binding.
Scholars of comparative law and economists promoting the legal origins theory usually subdivide civil law into four distinct groups:

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  French civil law: in France, the Benelux countries, Italy, Romania, Spain and former colonies of those countries;
  
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  German civil law: in Germany, Austria, Russia, Switzerland, Estonia, Latvia, Bosnia and Herzegovina, Croatia, Kosovo*, North Macedonia, Montenegro, Slovenia, Serbia, Greece, Portugal and its former colonies, Turkey, and East Asian countries including Japan, South Korea, and Taiwan (Republic of China);
  
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  Scandinavian civil law: in Denmark, Norway, and Sweden. As historically integrated into the Scandinavian cultural sphere, Finland and Iceland also inherited the system.
  
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  Law of the People's Republic of China: a mixture of civil law and socialist law in use in the People's Republic of China.
  

However, some of these legal systems are often and more correctly said to be of hybrid nature:

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  Napoleonic to Germanistic influence (Italian civil law)
  

The Italian civil code of 1942 replaced the original one of 1865, introducing germanistic elements due to the geopolitical alliances of the time.^[7] The Italian approach has been imitated by other countries including Portugal (1966), the Netherlands (1992), Lithuania (2000), Brazil (2002) and Argentina (2014). Most of them have innovations introduced by the Italian legislation, including the unification of the civil and commercial codes.^[8]

• 
  Germanistic to Napoleonic influence (Swiss civil law)
  

The Swiss civil code is considered mainly influenced by the German civil code and partly influenced by the French civil code. The civil code of the Republic of Turkey is a slightly modified version of the Swiss code, adopted in 1926 during Mustafa Kemal Atatürk's presidency as part of the government's progressive reforms and secularization.