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The world’s legal systems are mainly comprised of three basic systems – common law, civil law, and religious law. Civil law or common law are the systems employed by most major business markets. Below are a few notes on their distinctive features followed by a cheat sheet for the countries that operate in these systems.
Common Law: Common law’s main feature is the idea of judge-made decisions setting legal precedent. The basic principle is that it is unfair to treat similar facts differently. Thus, prior court decisions have precedential authority. Common law was developed in England and can generally be seen throughout the British Empire.
Civil Law: Civil Law’s distinctive feature is it is interpreted from a referable system rather than developed by previous court-made decisions. This system of law comes from the Romans and can generally be seen throughout Europe.
Below is a list of countries in alphabetical order that follow either the common law or civil law system. Please note, many countries have localized versions of these systems due to their histories and influences.
England and Wales
Common Law
Northern Ireland
Common Law
American Samoa
Common Law
Antigua and Barbuda
Common Law
Bosnia and Herzegovina
Civil Law
British Virgin Islands
Common Law
Cayman Islands
Common Law
Central African Republic
Civil Law
Democratic Republic of the Congo
Civil Law
Dominican Republic
Civil Law
Equatorial Guinea
Civil Law
Marshall Islands
Common Law
People's Republic of China
Civil Law
Republic of the Congo
Civil Law
Saint Kitts and Nevis
Common Law
Saint Vincent and the Grenadines
Common Law
São Tomé e Príncipe
Civil Law
Taiwan (Republic of China)
Civil Law
Trinidad and Tobago
Common Law
United States – Louisiana
Civil Law
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