Editing List of national legal systems (section)

==Pluralistic systems==<!-- This section is linked from [[Common law]] -->

===Civil law and canon law===
{{main|Canon law (Catholic Church)}}
[[Canon law]] is not divine law, properly speaking, because it is not found in revelation. Instead, it is seen as human law inspired by the word of God and applying the demands of that revelation to the actual situation of the church. [[Canon law]] regulates the internal ordering of the [[canon law (Catholic Church)|Catholic Church]], the [[Eastern Orthodox Church]] and the [[Anglican Communion]]. Canon law is amended and adopted by the legislative authority of the church, such as [[episcopal conference|councils of bishops]], individual bishops for their respective sees, the [[Pope]] for the entire Catholic Church, and the British Parliament for the [[Church of England]].
{| style="width:100%;" class="wikitable"
|-
! style="width:175px;"|Country
! Description
|-
| {{flagicon|Vatican City}} [[Law of Vatican City|Vatican City]]
| Based on [[Roman law|Roman]] & [[Law of Italy|Italian]] civil law and [[canon law (Catholic Church)|Catholic canon law]]<ref>{{Cite web|title=Pope Francis reforms Vatican City courts with new law|url=https://www.catholicnewsagency.com/news/43869/pope-francis-reforms-vatican-city-courts-with-new-law|access-date=2021-02-16|website=Catholic News Agency|language=en}}</ref>
|}

===Civil law and common law===
{| style="width:100%;" class="wikitable"
|-
! style="width:130px;"|Country
! Description
|-
| {{flagicon|Botswana}} [[Law of Botswana|Botswana]]
| Based on [[Law of South Africa|South African law]]. An 1891 proclamation by the [[High Commissioner for Southern Africa]] applied the law of the [[British Cape Colony|Cape Colony]] (now part of South Africa) to the [[Bechuanaland Protectorate]] (now Botswana).<ref name=pain>{{cite journal |title=The reception of English and Roman-Dutch law in Africa with reference to Botswana, Lesotho and Swaziland |first=JH |last=Pain |journal=The Comparative and International Law Journal of Southern Africa |volume=11 |number=2 |date=July 1978 |pages=137–167 }}</ref>
|-
| {{flagicon|Cameroon}} [[Laws of Cameroon|Cameroon]]
| Mixture of French civil law system and English common law (After [[World War I]], Cameroon was ruled by [[France]] and the [[United Kingdom]] as a [[League of Nations mandate]] then a [[United Nations trust territories|United Nations trust territory]] from 1916 to 1961)
|-
| {{flagicon|Cyprus}} [[Law of Cyprus|Cyprus]]
| Based on English common law (Cyprus was a British colony 1878–1960), with admixtures of French and Greek civil and public law, Italian civil law, Indian contract law, [[Greek Orthodox]] canon law and Muslim religious law.
|-
| {{flagicon|Eswatini}} [[Law of Eswatini|Eswatini]]
| Based on [[Law of South Africa|South African law]]. A 1907 proclamation by the [[High Commissioner for Southern Africa]] applied the Roman-Dutch common law of the [[Transvaal Colony]] (now part of South Africa) to the [[Swaziland Protectorate]] (now Eswatini).<ref name=pain/>
|-
| {{flagicon|Guyana}} [[Law of Guyana|Guyana]]
| Guyana follows a mixed legal system, a combination of civil law & common law.<ref>{{cite web |last1=Errol |first1=A. Adams |title=Guyana Law and Legal Research |url=https://www.nyulawglobal.org/globalex/Guyana.html |publisher=Hauser Global Law School Program, New York University School of Law |year=2020}}</ref>
|-
|{{flagicon|India}} [[Law of India|India]]
| In post-independence India, the Uniform Penal Code throughout India and [[Goa civil code|civil code to residents of Goa]]. The [[Bharatiya Nyaya Sanhita]], the [[Bharatiya Nagarik Suraksha Sanhita]] and the [[Bharatiya Sakshya Act, 2023]] amendment bills with minor changes.<ref name=in1/><ref name=in2/> While [[Hindu personal law]] based on customary laws of [[Indian religions]] and [[Muslim personal law]] based on [[hanafi]] school are currently used,<ref>{{cite web|title=Religious conversion: HC query raises more question marks|url=https://timesofindia.indiatimes.com/city/jodhpur/religious-conversion-hc-query-raises-more-question-marks/articleshow/61473880.cms|work=The Times of India|access-date=1 December 2017}}</ref> the Indian government is promoting a [[Uniform Civil Code]] that applies to all citizens.<ref>{{cite web |title=Modi's party set to bring contentious common civil laws in India through states |url=https://www.reuters.com/world/india/modis-party-set-bring-contentious-common-civil-laws-india-through-states-2024-01-31/ |publisher=Reuters |access-date=January 31, 2024}}</ref>
|-
| {{flagicon|Kenya}} [[Law of Kenya|Kenya]]
| Based on English Common Law and Civil law as well as the country's customary law.
|-
| {{flagicon|Lesotho}} [[Law of Lesotho|Lesotho]]
| Based on [[Law of South Africa|South African law]]. An 1884 proclamation by the [[High Commissioner for Southern Africa]] applied the law of the [[British Cape Colony|Cape Colony]] (now part of South Africa) to [[Basutoland]] (now Lesotho).<ref name=pain/>
|-
| {{flagicon|Louisiana}} [[Louisiana law|Louisiana]]<br>({{flagicon|United States}} U.S.)
| Based on French and Spanish civil law, but federal laws (based on common law) are also in effect in Louisiana because of the federal constitution's [[Supremacy Clause]]. However, Louisiana's criminal law, procedural law and administrative law is predominantly based on the common law tradition.
|-
| {{flagicon|Malta}} [[Law of Malta|Malta]]
|Initially based on [[Roman Law]] and eventually progressed to the Code de Rohan, the [[Napoleonic Code]] with influences from Italian Civil Law. English common law however is also a source of Maltese Law, most notably in public law.
|-
| {{flagicon|Mauritius}} [[Law of Mauritius|Mauritius]]
| Laws governing the Mauritian penal system are derived partly from [[French civil law]] and [[British common law]].<ref>{{cite web|url=http://www.mongabay.com/history/mauritius/mauritius-penal_system_8147.html|title=Mauritius-Penal System|access-date=19 March 2018}}</ref>
|-
| {{flagicon|Namibia}} [[Law of Namibia|Namibia]]
| Based on [[Law of South Africa|South African law]]. South Africa conquered [[South-West Africa]] (now Namibia) in 1915, and a 1919 proclamation by the [[Governor-General of South Africa|Governor-General]] applied the law of the [[Cape Province]] of South Africa to the territory.<ref>{{cite web |url=http://www.nyulawglobal.org/globalex/Namibia1.htm |first1=Geraldine Mwanza |last1=Geraldo |first2=Isabella |last2=Nowases |title=Researching Namibian Law and the Namibian Legal System |date=April 2010 |access-date=7 May 2013}}</ref>
|-
| {{flagicon|Philippines}} [[Law of the Philippines|Philippines]]
| Based on Spanish law; influenced by U.S. common law after 1898 [[Spanish–American War|Spanish–]] and [[Philippine–American War]]s, personal law based on [[sharia]] law applies to Muslims.
|-
| {{flagicon|Puerto Rico}} [[Law of Puerto Rico|Puerto Rico]]<br>({{flagicon|United States}} U.S.)
| Based on Spanish law; influenced by U.S. common law after 1898 (victory of the U.S. over Spain in the Spanish–American War of 1898 and cession of Puerto Rico to the U.S.); federal laws (based on common law) are in effect because of federal Supremacy Clause.
|-
| {{flagicon|Quebec}} [[Quebec law|Quebec]]<br>({{flagicon|Canada}} [[Law of Canada|Canada]])
| After the 1763 [[Treaty of Paris (1763)|Treaty of Paris]] awarded [[Canada (New France)|French Canada]] to Great Britain, the British initially attempted to impose English Common Law. In 1774, as a result of a ruling by the British courts in ''[[Campbell v Hall]]'' about the status of legal systems found in acquired territories, the British Parliament passed the [[Quebec Act]], which preserved French [[Civil law (legal system)|civil law]] for [[private law]] while keeping and reserving English [[common law]] for public law including criminal prosecution. Codification occurred in 1866 with the enactment of the ''[[Civil Code of Lower Canada]]'' ([[French language|French]]: ''Code civil du Bas-Canada''), which continued in force when the modern Province of Quebec was created at Confederation in 1867. Subsequently, the ''[[Civil Code of Quebec]]'' ([[French language|French]]: ''Code civil du Québec'') came into effect on 1 January 1994, and is the [[civil code]] currently in force. Canadian (federal) criminal law in force in Quebec is based on common law, but federal statutes of or relating to private law take into account the bijuridical nature of Canada and use both common law and civil law terms where appropriate.
|-
| {{flagicon|Saint Lucia}} [[Law of Saint Lucia|Saint Lucia]]
|
|-
| {{flagicon|Scotland}} [[Scots law|Scotland]]
| Based on [[Roman law|Roman]] and continental law, with common law elements dating back to the [[Legal institutions of Scotland in the High Middle Ages|High Middle Ages]].<ref>This definition is partly disputed&nbsp;– Thomson, Stephen, [http://digitalcommons.law.lsu.edu/jcls/vol7/iss1/3/ ''Mixed Jurisdiction and the Scottish Legal Tradition: Reconsidering the Concept of Mixture''] (2014) 7(1) [[Journal of Civil Law Studies]] 51–91</ref>
|-
| {{flagicon|Seychelles}} [[Law of Seychelles|Seychelles]]
| The substantive civil law is based on the French Civil Code. Otherwise, the criminal law and court procedure are based on the English common law. See [http://sites.google.com/site/theseychelleslegalenvironment/legal-system Seychelles Legal Environment].
|-
| {{flagicon|South Africa}} [[Law of South Africa|South Africa]]
| An amalgam of [[Roman-Dutch law|Roman-Dutch civil law]] and English [[common law]], as well as [[Customary Law]].
|-
| {{flagicon|Sri Lanka}} [[Law of Sri Lanka|Sri Lanka]]
| An amalgam of English common law, [[Roman-Dutch law|Roman-Dutch civil law]] and [[Customary Law]]
|-
| {{flagicon|Thailand}} [[Law of Thailand|Thailand]]
| The Thai legal system became an amalgam of German, Swiss, French, English, Japanese, Italian, Indian and American laws and practices. Even today, Islamic laws and practices exist in four southern provinces. Over the years, Thai law has naturally taken on its own Thai identity.
|-
| {{flagicon|Vanuatu}} [[Law of Vanuatu|Vanuatu]]
| Consists of a mixed system combining the legacy of English common law, French civil law and indigenous customary law.
|-
| {{flagicon|Zimbabwe}} [[Law of Zimbabwe|Zimbabwe]]
| Based on [[Law of South Africa|South African law]]. An 1891 proclamation by the [[High Commissioner for Southern Africa]] applied the law of the [[British Cape Colony|Cape Colony]] (now part of South Africa) to [[Southern Rhodesia]] (now Zimbabwe).
|}

===Civil law and sharia law===
{| style="width:100%;" class="wikitable"
|-
! style="width:130px;"|Country
! Description
|-
| {{flagicon|Algeria}} [[Law of Algeria|Algeria]]
|
|-
| {{flagicon|Bahrain}} [[Law of Bahrain|Bahrain]]
|
|-
| {{flagicon|Comoros}} [[Law of Comoros|Comoros]]
|
|-
| {{flagicon|Djibouti}} [[Law of Djibouti|Djibouti]]
|
|-
| {{flagicon|Egypt}} [[Egyptian judicial system|Egypt]]
|Family Law (personal Statute) for Muslims based on Islamic Jurisprudence, Separate Personal Statute for non-Muslims, and all other branches of Law are based on French civil law system
|-
| {{flagicon|Eritrea}} [[Law of Eritrea|Eritrea]]
|Only applies to Muslims for personal matters
|-
|{{flagicon|Indonesia}} [[Law of Indonesia|Indonesia]]
|Based on [[Napoleonic Code|Napoleonic-Dutch civil law]], mixed with Islamic [[sharia]] law (personal matters only), and [[Customary Law]]. 
|-
| {{flagicon|Jordan}} [[Law of Jordan|Jordan]]
| Mainly based on [[French Civil Code]] and Ottoman [[Majalla]], Islamic law applicable to family law
|-
| {{flagicon|Mauritania}} [[Law of Mauritania|Mauritania]]
| Mix of Islamic law and [[French Civil Code]]s, Islamic law largely applicable to both criminal, family law, and other forms of personal laws such as disputes.
|-
|{{flagicon|Mauritius}} [[Legal system of Mauritius|Mauritius]]
| Civil law and sharia personal law for Muslims. 
|-
| {{flagicon|Morocco}} [[Law of Morocco|Morocco]]
| Based on Islamic law and French and Spanish civil law system. Islamic law is mainly for personal matters and Jews use Halakha. 
|-
| {{flagicon|Oman}} [[Law of Oman|Oman]]
|
|-
| {{flagicon|Qatar}} [[Law of Qatar|Qatar]]
| Based on Islamic law and the Egyptian civil law system (after the French civil law system)
|-
| {{flagicon|Syria}} [[Law of Syria|Syria]]
|Mainly based on [[French Civil Code]]. Islamic law is applicable to family law. Non-Muslims follow their own family laws.
|-
| {{flagicon|United Arab Emirates}} [[Law of United Arab Emirates|United Arab Emirates]]
| Mixed legal system, based on Islamic law and the Egyptian civil law system (after the French civil law system). The UAE adopts a dual legal system of civil and Sharia.<ref>{{cite web |title=The Federal Judiciary |url=https://u.ae/en/about-the-uae/the-uae-government/the-federal-judiciary#:~:text=and%20Penalties%20Law-,Mixed%20legal%20system,(the%20system%20of%20law). |publisher=The UAE Government |year=2022}}</ref>
|}

===Common law and sharia law===
{| style="width:100%;" class="wikitable"
|-
! style="width:130px;"|Country
! Description
|-
| {{flagicon|Bangladesh}} [[Law of Bangladesh|Bangladesh]]
| Based on English common law, personal law based on sharia law applies to Muslims.
|-
| {{flagicon|Brunei}} [[Brunei]]
|
|-
| {{flagicon|The Gambia}} [[The Gambia]]
|
|-
| {{flagicon|Malaysia}} [[Law of Malaysia|Malaysia]]
| Based on English common law, personal law based on [[sharia]] law applies to Muslims (Not used on non-Muslims).
|-
| {{flagicon|Nigeria}} [[Law of Nigeria|Nigeria]]
| Common law is used at the federal level and in most states, [[Sharia in Nigeria|Sharia is applied in some northern states]].
|-
| {{flagicon|Pakistan}} [[Law of Pakistan|Pakistan]]
| Based on English common law, some Islamic law (sharia) applications in [[inheritance]]. Formerly [[Tribal Law]] in the [[Federally Administered Tribal Areas, Pakistan|FATA]].<ref name=pk/>
|}