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The section on Civil Law has serious problems in the third and fourth sentences. Right now, I would recommend reworking them from the ground up, but scrapping them and starting over doesn't seem awful either. They are an utter disaster and do nothing but confuse anyone interested in the topic. 64.131.169.110 ( talk) 00:36, 9 October 2013 (UTC)
I'm suggesting this should be merged with law because, the fact is, you can't talk about law without situating the law within a legal system. PullUpYourSocks 03:47, 9 December 2005 (UTC)
India's is a curious case. Before the coming of the British, local and private, as well as Caste laws were prevalent throughout India. Imperial conquerers from time to time instituted their own legal codes. After the coming of the British, Indian laws were codified for better administration and dispute resolution. Many of the laws thus codified and instituted were based on English Common Law. However, the point to be taken is that all laws were codified, and only then were they dispensed. If we just look at the Common Law definition given in Wikipedia:
"The common law forms a major part of the law of many countries, especially those with a history as British territories or colonies. It is notable for its inclusion of extensive non-statutory law reflecting a consensus of centuries of judgments by working jurists. ... One is used to distinguish the authority that promulgated a particular proposition of law: in the United States, we typically have "statutes" enacted by a legislature, "regulations" promulgated by executive branch agencies pursuant to a delgation of rule-making authority from a legislature, and "common law" decisions issued by courts (or quasi-judicial tribunals within agencies) that discuss and decide the fine distinctions in statutes and regulations. See statutory law and non-statutory law."
we find that the Common Law has mostly been non-statutory customary law. However, Indian laws during the centuries since the coming of the British have been what is called 'Positive law', ie, laws made by and promulgated by a secular known authority. There are certain sectors of Indian laws where some customary and what are called 'Personal laws' are prevalent, like in issues relating to marriage, inheritance, divorce, adoption, etc. Even there proper statutes have been made that dictate and regulate the jurisdiction of personal laws. Article 44 of the Constitution enjoins upon the government to ensure that a Common Civil Code is ushered throughout the land, but that has not yet come about, and Common Civil Code remains a most contested issue in Indian Polity. India's constitution was written after Indian independence, and was promulgated on 26 January 1950, and the constitution remains the primary legal document. The Indian Civil Code, the Indian Penal Code and Civil Procedure Codes are based on English made laws (all of which were made especially for India, although heavily borrowing from English system), and they have been amended many times. This puts India in a very unique position. Of course there are remnants of Common law as usually defined, but I think India should more rightly be put under the Civil law system.
Indian contract law in Cyprus? Is it real? Sources? Legislator ( talk) 10:33, 29 September 2010 (UTC)
The Pakistani legal system is based on the common law. There are a few areas (inheitance for one) which are based on Islamic law to a certain extent, but
1) The Pakistani Penal system is based on the Indian Penal Code of 1860. The civil procedure codes are still in effect.
2) Pakistan retains an adversarial court procedure.
Just added in NZ in the common law table, might put something about Maori land law later, but new to Wikipedia editing so I want to check things first :-) Alphamatrix 03:30, 12 April 2006 (UTC)
european union makes directives. what kind of law is this. Will a european law be differently apllied in UK and in France?
I'm moving Malta from Civil Law to mixed for the following reasons:
-- 3247 13:21, 16 September 2006 (UTC)
The map shows Argentina as mixed common and civil but the article states it is just civil. Which is it? Also, Chile overhauled their trial system so that it is now adversarial. Show we include this as mixed now? KingOfAfrica 13:44, 21 September 2006 (UTC)
To say that Canada is common law except civil law in Quebec is a little misleading.
For criminal law purposes, common law is used throughout Canada, including quebec. For civil law purposes (by this I mean private law) common law is used everywhere except Quebec. Quebec does use a napoleonic system for private law, but common law for criminal law.
If someone could figure out how to work this in there that'd be great.
I've edited the recent edit which suggests that Quebec only became a civil law jurisdiction in 1866, with the enactment of the Civil Code of Lower Canada. While codification is one of the characteristics of most modern civil law jurisdictions, the concept of the civil law is not restricted to codified systems - another defining feature of civil law systems is that they are ultimately derived from the Roman law, as elaborated over the centuries. Quebec did not become a civil law jurisdiction for the first time in 1866, any more than France became a civil jurisdiction for the first time in 1804, with the adoption of the Napoleonic Code. Codification was a modern development in the long history of the civil law system. Mr Serjeant Buzfuz ( talk) 12:27, 23 September 2011 (UTC)
I'd like to suggest that the sections about 'customary law' be removed. The reason is that I just don't think it's an actual legal system in its own right. Custom is certainly a source of law, and an important one, but it doesn't constitute a legal system. The only two examples given are Andorra and Mongolia. This is a link to law in Mongolia, which I googled in about 2 seconds, showing a distinct lack of 'custom' - it's a civil code based jurisdiction. As for Andorra, it's a European country, and I bet it's got a civil law system much like the places around it. If you wanted you could call the common law customary law under the definition given on the customary law page, and you could call England a mixed system with custom and common law: think of all the Parliamentary procedures, or the custom that the monarch doesn't sack the elected government (since 1707 I think). I'm sure that you can easily remove it from the page, and it'd make the page far simpler, neater and more accurate. Would it be okay for me to go ahead on this? Wikidea 04:10, 14 January 2007 (UTC)
I just stumbled on this article. I don't have any background in law and after looking at the map with legal systems, I don't really understand what customary law is. There are inconsistencies between the map, the lists of countries and the main text in the article. What do you think is the right thing to do to fix that? -- Martinkunev ( talk) 00:03, 27 March 2016 (UTC)
The Louisiana section implies that the Napoleonic code came with the Louisiana territory when it was purchased. This is not the case. The Spanish civil code was in effect in the Louisiana territory when it was purchased from Napoleon. The state of Louisiana later voluntarily accepted the French civil code (not truly the Napoleonic code, but that's a fine point). The purchase was completed in 1804 and no true change in law (other than the partial importation of US Common law) occurred prior to 1808, when the Civil Code was drawn up based on French, Spanish and Napoleonic code - with French being the primary influence (France having recently completed all the work of writing up a fresh new code).
Geofferic 17:02, 31 January 2007 (UTC)
"Federal court system based on napoleonic code not english legal system"
Its lack of capitals makes it look like a hasty vandal's addition. -- Czar Kirk ( talk) 02:04, 5 February 2008 (UTC)
No, I'll amend it. http://en.wikipedia.org/wiki/Law_of_the_United_States quite clearly states that Federal law is based on English Common law, it has not diverged rather it only doesn't accept rulings from the British courts unlike the Commonwealth (Australia, Canada, New Zealand and the like). Twobells ( talk) 15:56, 15 August 2011 (UTC)
The Legal System in Bahrain
In 2001 the Kingdom of Bahrain changed from a Common Law - Sharia hybrid to a Civil law system. —Preceding unsigned comment added by 82.194.62.230 ( talk) 08:09, 4 March 2008 (UTC)
On page Civil_law_(legal_system) legal origins theory suggests four subgroups, as opposed to the three subgroups on Legal_systems_of_the_world adding Chinese law. The two pages should be reconciled. —Preceding unsigned comment added by Biccat ( talk • contribs) 21:26, 27 March 2008 (UTC)
Syria's legal system is identical to that of Egypt, where it is an amalgam of French civil code and Islamic Sharia.
http://www.nationsencyclopedia.com/Asia-and-Oceania/Syria-JUDICIAL-SYSTEM.html http://www.law.emory.edu/ifl/legal/syria.htm https://www.cia.gov/library/publications/the-world-factbook/geos/sy.html —Preceding unsigned comment added by Sms1981 ( talk • contribs) 00:50, 11 June 2008 (UTC)
What kind of laws are the council of elders (Somalia, ...), ayllu (bolivia), and the general fono (tokelau), ... ? They also aren't mentioned in article —Preceding unsigned comment added by 91.182.176.5 ( talk) 11:21, 19 June 2009 (UTC)
This map is overly simplistic when compared to this article. For example, Pakistan and Bangladesh are described as being both a mix of religious and common law in this article but in the map Pakistan is marked as common law and Bangladesh is marked as Islamic law. Also, Mauritania and Egypt are equally a mix of civil law and Islamic law but Egypt is marked as only civil and Mauritania as only Islamic. Shouldn't there be a lot of stripes to the map? Munci ( talk) 19:18, 14 July 2010 (UTC)
Sorry for my ignorance, but is there a difference between Islamic Law and Sharia? The Wikipedia article for Islamic Law simply points to the Sharia page, so I imagine there isn't. If there isn't a difference this page should just have one term, either Sharia or Islamic Law, instead of arbitrarily using both. --Gabe 216.165.95.70 ( talk) 21:26, 24 October 2010 (UTC)
Show up bikromshah 02:03, 26 February 2020 (UTC) — Preceding unsigned comment added by Bikromshah ( talk • contribs)
Law of Vatican is described in Codex Iuris Canonici, the latest version from 1983, based mostly on older so called Pio-Benedictine from 1917. In the end it can obviously be traced to religious foundation but nevertheless it is a case of Civil Law, isn't it? Errarel ( talk) 20:22, 22 February 2011 (UTC)
Far too much weight lol, it is only Professor Makdisi and another Islamic scholar Omar Faruk who believes that, that vast majority know otherwise and the article should reflect that, I'll update. Twobells ( talk) 15:17, 15 August 2011 (UTC)
Each of the states in the USA has their own legal system so it might make sense to list them separately. Scotland and England are listed separately but neither is a sovereign state. Count Truthstein ( talk) 14:47, 25 March 2012 (UTC)
What is Scandinavian Law? Concept, Characteristics, Future (Ulf Bernitz). I think this would help because there isn't any much info on legal systems of Scandinavian countries. Komitsuki ( talk) 10:43, 10 August 2014 (UTC)
In recent Scandinavian legal writing, the topic of legal classification has been treated, i.a., by Michael Bogdan, professor at Lund University, in his textbook Komparativ rättskunskap12 (Comparative Legal Science). Similarly to Professor Jacob Sundberg of Stockholm University,13 Bogdan stresses that Nordic law belongs primarily to the family of the legal systems of Continental Europe, showing far more similarities to these systems than to those belonging to the common law family. On the other hand, Ditlev Tamm, a Danish professor of legal history, has favoured the view Scandinavian law should be regarded as a separate legal family, pointing at three key factors: the limited importance of legal formalities, the lack of modern codifications and the absence of an actual reception of Roman law.14
I am not up to date on the admission of the 51st state so could someone enlighten me? My wonderment comes from the "Common law" section and wikitable that list under the United States, in the description column: Federal courts and 50 states use the legal system based on English common law.... It further states: State law in the U.S. state of Louisiana is based on French and Spanish civil law (see above), but doesn't say exactly where. The point is that as worded there are 50 states practicing Common law "and" the state of Louisiana that practices Civil law. According to this the United States should be listed in both sections (Civil and Common) with Louisiana the only entry under Civil. Louisiana actually has to practice both forms of law. WHAT! you might say. The fact is that if the United States Government practices "Common Law", and a Supreme Court decision is passed down that a Louisiana "Civil law" is unconstitutional, then the Federal law takes precedent and Louisiana must adhere to this. Anyway, I am still wondering about the 51st state. Otr500 ( talk) 18:30, 28 December 2014 (UTC)
What's the advantage of including this second map? I note that it mistakenly depicts Quebec as including Labrador, New Brunswick and Nova Scotia; who knows what other errors it has. — Tamfang ( talk) 07:08, 7 June 2015 (UTC)
I too found this map filled with imprecisions.
I'll add these observations to the image's talk page as well. Pqnlrn ( talk) 04:51, 14 February 2016 (UTC)
The qualified reader of the present summary will be astounded to learn the following "facts":-
In some jurisdictions, ... statutes may overrule judicial decisions. Well, in all common law jurisdictions statutes may overrule judicial decisions. Name a country where it isn't so.
In some jurisdictions, judicial decisions may decide what meaning is contained within the statutory provisions. In all jurisdictions judicial decisions may (and do) decide what a statute means. Nacwiis.
Statutes were allowed to be made by the government. Not unless it was a dictatorship.
Common law developed in England, influenced by Anglo-Saxon law and to a much lesser extent by the Norman conquest of England ...' The influence of Anglo-Saxon law is minimal. The Norman influence was much greater, not much lesser. But neither of those have had any real influence on the common law, which did not start to develop until the reign of Henry II, well after the end of the Norman dynasty.
... which introduced legal concepts from Norman law, which, in turn, had its origins in Salic law. It makes you blush. Next time I'm in court I must make sure to cite some of that Salic law.
Common law was later inherited by the Commonwealth of Nations, and almost every former colony of the British Empire has adopted it (Malta being an exception). Why not mention the United States of America? Isn't that kind of an important common law country? Who says that South Africa (Roman-Dutch law) and Sri Lanka (Roman-Dutch law) are common law systems? BTW, I'm not an expert on Malta, but if this bit is true the author of Law of Malta will have to change it some.
Ttocserp 13:46, 5 August 2015 (UTC) — Preceding unsigned comment added by Prkprescott ( talk • contribs)
Ive updated the article as reliable sources state that the two major legal systems can equally hold the 'most widespread' tag. Common law by most number of jurisdictions and population empoying the system and the legal structure that covers the most landmass which is Civil law, subsequently, I've updated the article to reflect that, regards. Twobells t@lk 14:58, 30 August 2015 (UTC)
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Hey guys, I noticed that Singapore is not added into the list of countries. The legal system in Singapore is the British common law. — Preceding unsigned comment added by 202.161.33.20 ( talk) 05:20, 2 April 2018 (UTC)
Is it really important to magnify Europe to this degree? It would make sense if it were less homogeneous, but there are not many legal systems in Europe, and the ones that are different are easily seen at normal magnification. Many small countries in places outside of Europe are smaller than Ireland, and are not magnified. The only place I can really see that needs to be magnified is isolated, and these can be shown with lines or arrows.
Jcbookman ( talk) 23:03, 27 August 2020 (UTC)
I got confussion 154.74.127.67 ( talk) 11:00, 23 November 2021 (UTC)
The map of legal systems talks about "customary" law, but this appears for all intents and purposes to be synonymous with common law (law defined by tradition/custom/precedent/common views)? How does it differ? 2A02:C7C:C47D:8700:8854:71A:DCF6:DE15 ( talk) 22:21, 23 February 2023 (UTC)
where's indonesia? you forgot to mention indonesia in this article, okay? i think the legal system of indonesia is consisting of a mixture between civil law, sharia, and customary law, that's it. I hope anyone can edit this article and add indonesia following the respective application. the end. correct me if i am wrong. 2404:8000:1027:85F6:1193:21A2:D1B3:FBAD ( talk) 11:02, 16 May 2023 (UTC)
This is the
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List of national legal systems article. This is not a forum for general discussion of the article's subject. |
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A summary of this article appears in Law. |
The section on Civil Law has serious problems in the third and fourth sentences. Right now, I would recommend reworking them from the ground up, but scrapping them and starting over doesn't seem awful either. They are an utter disaster and do nothing but confuse anyone interested in the topic. 64.131.169.110 ( talk) 00:36, 9 October 2013 (UTC)
I'm suggesting this should be merged with law because, the fact is, you can't talk about law without situating the law within a legal system. PullUpYourSocks 03:47, 9 December 2005 (UTC)
India's is a curious case. Before the coming of the British, local and private, as well as Caste laws were prevalent throughout India. Imperial conquerers from time to time instituted their own legal codes. After the coming of the British, Indian laws were codified for better administration and dispute resolution. Many of the laws thus codified and instituted were based on English Common Law. However, the point to be taken is that all laws were codified, and only then were they dispensed. If we just look at the Common Law definition given in Wikipedia:
"The common law forms a major part of the law of many countries, especially those with a history as British territories or colonies. It is notable for its inclusion of extensive non-statutory law reflecting a consensus of centuries of judgments by working jurists. ... One is used to distinguish the authority that promulgated a particular proposition of law: in the United States, we typically have "statutes" enacted by a legislature, "regulations" promulgated by executive branch agencies pursuant to a delgation of rule-making authority from a legislature, and "common law" decisions issued by courts (or quasi-judicial tribunals within agencies) that discuss and decide the fine distinctions in statutes and regulations. See statutory law and non-statutory law."
we find that the Common Law has mostly been non-statutory customary law. However, Indian laws during the centuries since the coming of the British have been what is called 'Positive law', ie, laws made by and promulgated by a secular known authority. There are certain sectors of Indian laws where some customary and what are called 'Personal laws' are prevalent, like in issues relating to marriage, inheritance, divorce, adoption, etc. Even there proper statutes have been made that dictate and regulate the jurisdiction of personal laws. Article 44 of the Constitution enjoins upon the government to ensure that a Common Civil Code is ushered throughout the land, but that has not yet come about, and Common Civil Code remains a most contested issue in Indian Polity. India's constitution was written after Indian independence, and was promulgated on 26 January 1950, and the constitution remains the primary legal document. The Indian Civil Code, the Indian Penal Code and Civil Procedure Codes are based on English made laws (all of which were made especially for India, although heavily borrowing from English system), and they have been amended many times. This puts India in a very unique position. Of course there are remnants of Common law as usually defined, but I think India should more rightly be put under the Civil law system.
Indian contract law in Cyprus? Is it real? Sources? Legislator ( talk) 10:33, 29 September 2010 (UTC)
The Pakistani legal system is based on the common law. There are a few areas (inheitance for one) which are based on Islamic law to a certain extent, but
1) The Pakistani Penal system is based on the Indian Penal Code of 1860. The civil procedure codes are still in effect.
2) Pakistan retains an adversarial court procedure.
Just added in NZ in the common law table, might put something about Maori land law later, but new to Wikipedia editing so I want to check things first :-) Alphamatrix 03:30, 12 April 2006 (UTC)
european union makes directives. what kind of law is this. Will a european law be differently apllied in UK and in France?
I'm moving Malta from Civil Law to mixed for the following reasons:
-- 3247 13:21, 16 September 2006 (UTC)
The map shows Argentina as mixed common and civil but the article states it is just civil. Which is it? Also, Chile overhauled their trial system so that it is now adversarial. Show we include this as mixed now? KingOfAfrica 13:44, 21 September 2006 (UTC)
To say that Canada is common law except civil law in Quebec is a little misleading.
For criminal law purposes, common law is used throughout Canada, including quebec. For civil law purposes (by this I mean private law) common law is used everywhere except Quebec. Quebec does use a napoleonic system for private law, but common law for criminal law.
If someone could figure out how to work this in there that'd be great.
I've edited the recent edit which suggests that Quebec only became a civil law jurisdiction in 1866, with the enactment of the Civil Code of Lower Canada. While codification is one of the characteristics of most modern civil law jurisdictions, the concept of the civil law is not restricted to codified systems - another defining feature of civil law systems is that they are ultimately derived from the Roman law, as elaborated over the centuries. Quebec did not become a civil law jurisdiction for the first time in 1866, any more than France became a civil jurisdiction for the first time in 1804, with the adoption of the Napoleonic Code. Codification was a modern development in the long history of the civil law system. Mr Serjeant Buzfuz ( talk) 12:27, 23 September 2011 (UTC)
I'd like to suggest that the sections about 'customary law' be removed. The reason is that I just don't think it's an actual legal system in its own right. Custom is certainly a source of law, and an important one, but it doesn't constitute a legal system. The only two examples given are Andorra and Mongolia. This is a link to law in Mongolia, which I googled in about 2 seconds, showing a distinct lack of 'custom' - it's a civil code based jurisdiction. As for Andorra, it's a European country, and I bet it's got a civil law system much like the places around it. If you wanted you could call the common law customary law under the definition given on the customary law page, and you could call England a mixed system with custom and common law: think of all the Parliamentary procedures, or the custom that the monarch doesn't sack the elected government (since 1707 I think). I'm sure that you can easily remove it from the page, and it'd make the page far simpler, neater and more accurate. Would it be okay for me to go ahead on this? Wikidea 04:10, 14 January 2007 (UTC)
I just stumbled on this article. I don't have any background in law and after looking at the map with legal systems, I don't really understand what customary law is. There are inconsistencies between the map, the lists of countries and the main text in the article. What do you think is the right thing to do to fix that? -- Martinkunev ( talk) 00:03, 27 March 2016 (UTC)
The Louisiana section implies that the Napoleonic code came with the Louisiana territory when it was purchased. This is not the case. The Spanish civil code was in effect in the Louisiana territory when it was purchased from Napoleon. The state of Louisiana later voluntarily accepted the French civil code (not truly the Napoleonic code, but that's a fine point). The purchase was completed in 1804 and no true change in law (other than the partial importation of US Common law) occurred prior to 1808, when the Civil Code was drawn up based on French, Spanish and Napoleonic code - with French being the primary influence (France having recently completed all the work of writing up a fresh new code).
Geofferic 17:02, 31 January 2007 (UTC)
"Federal court system based on napoleonic code not english legal system"
Its lack of capitals makes it look like a hasty vandal's addition. -- Czar Kirk ( talk) 02:04, 5 February 2008 (UTC)
No, I'll amend it. http://en.wikipedia.org/wiki/Law_of_the_United_States quite clearly states that Federal law is based on English Common law, it has not diverged rather it only doesn't accept rulings from the British courts unlike the Commonwealth (Australia, Canada, New Zealand and the like). Twobells ( talk) 15:56, 15 August 2011 (UTC)
The Legal System in Bahrain
In 2001 the Kingdom of Bahrain changed from a Common Law - Sharia hybrid to a Civil law system. —Preceding unsigned comment added by 82.194.62.230 ( talk) 08:09, 4 March 2008 (UTC)
On page Civil_law_(legal_system) legal origins theory suggests four subgroups, as opposed to the three subgroups on Legal_systems_of_the_world adding Chinese law. The two pages should be reconciled. —Preceding unsigned comment added by Biccat ( talk • contribs) 21:26, 27 March 2008 (UTC)
Syria's legal system is identical to that of Egypt, where it is an amalgam of French civil code and Islamic Sharia.
http://www.nationsencyclopedia.com/Asia-and-Oceania/Syria-JUDICIAL-SYSTEM.html http://www.law.emory.edu/ifl/legal/syria.htm https://www.cia.gov/library/publications/the-world-factbook/geos/sy.html —Preceding unsigned comment added by Sms1981 ( talk • contribs) 00:50, 11 June 2008 (UTC)
What kind of laws are the council of elders (Somalia, ...), ayllu (bolivia), and the general fono (tokelau), ... ? They also aren't mentioned in article —Preceding unsigned comment added by 91.182.176.5 ( talk) 11:21, 19 June 2009 (UTC)
This map is overly simplistic when compared to this article. For example, Pakistan and Bangladesh are described as being both a mix of religious and common law in this article but in the map Pakistan is marked as common law and Bangladesh is marked as Islamic law. Also, Mauritania and Egypt are equally a mix of civil law and Islamic law but Egypt is marked as only civil and Mauritania as only Islamic. Shouldn't there be a lot of stripes to the map? Munci ( talk) 19:18, 14 July 2010 (UTC)
Sorry for my ignorance, but is there a difference between Islamic Law and Sharia? The Wikipedia article for Islamic Law simply points to the Sharia page, so I imagine there isn't. If there isn't a difference this page should just have one term, either Sharia or Islamic Law, instead of arbitrarily using both. --Gabe 216.165.95.70 ( talk) 21:26, 24 October 2010 (UTC)
Show up bikromshah 02:03, 26 February 2020 (UTC) — Preceding unsigned comment added by Bikromshah ( talk • contribs)
Law of Vatican is described in Codex Iuris Canonici, the latest version from 1983, based mostly on older so called Pio-Benedictine from 1917. In the end it can obviously be traced to religious foundation but nevertheless it is a case of Civil Law, isn't it? Errarel ( talk) 20:22, 22 February 2011 (UTC)
Far too much weight lol, it is only Professor Makdisi and another Islamic scholar Omar Faruk who believes that, that vast majority know otherwise and the article should reflect that, I'll update. Twobells ( talk) 15:17, 15 August 2011 (UTC)
Each of the states in the USA has their own legal system so it might make sense to list them separately. Scotland and England are listed separately but neither is a sovereign state. Count Truthstein ( talk) 14:47, 25 March 2012 (UTC)
What is Scandinavian Law? Concept, Characteristics, Future (Ulf Bernitz). I think this would help because there isn't any much info on legal systems of Scandinavian countries. Komitsuki ( talk) 10:43, 10 August 2014 (UTC)
In recent Scandinavian legal writing, the topic of legal classification has been treated, i.a., by Michael Bogdan, professor at Lund University, in his textbook Komparativ rättskunskap12 (Comparative Legal Science). Similarly to Professor Jacob Sundberg of Stockholm University,13 Bogdan stresses that Nordic law belongs primarily to the family of the legal systems of Continental Europe, showing far more similarities to these systems than to those belonging to the common law family. On the other hand, Ditlev Tamm, a Danish professor of legal history, has favoured the view Scandinavian law should be regarded as a separate legal family, pointing at three key factors: the limited importance of legal formalities, the lack of modern codifications and the absence of an actual reception of Roman law.14
I am not up to date on the admission of the 51st state so could someone enlighten me? My wonderment comes from the "Common law" section and wikitable that list under the United States, in the description column: Federal courts and 50 states use the legal system based on English common law.... It further states: State law in the U.S. state of Louisiana is based on French and Spanish civil law (see above), but doesn't say exactly where. The point is that as worded there are 50 states practicing Common law "and" the state of Louisiana that practices Civil law. According to this the United States should be listed in both sections (Civil and Common) with Louisiana the only entry under Civil. Louisiana actually has to practice both forms of law. WHAT! you might say. The fact is that if the United States Government practices "Common Law", and a Supreme Court decision is passed down that a Louisiana "Civil law" is unconstitutional, then the Federal law takes precedent and Louisiana must adhere to this. Anyway, I am still wondering about the 51st state. Otr500 ( talk) 18:30, 28 December 2014 (UTC)
What's the advantage of including this second map? I note that it mistakenly depicts Quebec as including Labrador, New Brunswick and Nova Scotia; who knows what other errors it has. — Tamfang ( talk) 07:08, 7 June 2015 (UTC)
I too found this map filled with imprecisions.
I'll add these observations to the image's talk page as well. Pqnlrn ( talk) 04:51, 14 February 2016 (UTC)
The qualified reader of the present summary will be astounded to learn the following "facts":-
In some jurisdictions, ... statutes may overrule judicial decisions. Well, in all common law jurisdictions statutes may overrule judicial decisions. Name a country where it isn't so.
In some jurisdictions, judicial decisions may decide what meaning is contained within the statutory provisions. In all jurisdictions judicial decisions may (and do) decide what a statute means. Nacwiis.
Statutes were allowed to be made by the government. Not unless it was a dictatorship.
Common law developed in England, influenced by Anglo-Saxon law and to a much lesser extent by the Norman conquest of England ...' The influence of Anglo-Saxon law is minimal. The Norman influence was much greater, not much lesser. But neither of those have had any real influence on the common law, which did not start to develop until the reign of Henry II, well after the end of the Norman dynasty.
... which introduced legal concepts from Norman law, which, in turn, had its origins in Salic law. It makes you blush. Next time I'm in court I must make sure to cite some of that Salic law.
Common law was later inherited by the Commonwealth of Nations, and almost every former colony of the British Empire has adopted it (Malta being an exception). Why not mention the United States of America? Isn't that kind of an important common law country? Who says that South Africa (Roman-Dutch law) and Sri Lanka (Roman-Dutch law) are common law systems? BTW, I'm not an expert on Malta, but if this bit is true the author of Law of Malta will have to change it some.
Ttocserp 13:46, 5 August 2015 (UTC) — Preceding unsigned comment added by Prkprescott ( talk • contribs)
Ive updated the article as reliable sources state that the two major legal systems can equally hold the 'most widespread' tag. Common law by most number of jurisdictions and population empoying the system and the legal structure that covers the most landmass which is Civil law, subsequently, I've updated the article to reflect that, regards. Twobells t@lk 14:58, 30 August 2015 (UTC)
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Hey guys, I noticed that Singapore is not added into the list of countries. The legal system in Singapore is the British common law. — Preceding unsigned comment added by 202.161.33.20 ( talk) 05:20, 2 April 2018 (UTC)
Is it really important to magnify Europe to this degree? It would make sense if it were less homogeneous, but there are not many legal systems in Europe, and the ones that are different are easily seen at normal magnification. Many small countries in places outside of Europe are smaller than Ireland, and are not magnified. The only place I can really see that needs to be magnified is isolated, and these can be shown with lines or arrows.
Jcbookman ( talk) 23:03, 27 August 2020 (UTC)
I got confussion 154.74.127.67 ( talk) 11:00, 23 November 2021 (UTC)
The map of legal systems talks about "customary" law, but this appears for all intents and purposes to be synonymous with common law (law defined by tradition/custom/precedent/common views)? How does it differ? 2A02:C7C:C47D:8700:8854:71A:DCF6:DE15 ( talk) 22:21, 23 February 2023 (UTC)
where's indonesia? you forgot to mention indonesia in this article, okay? i think the legal system of indonesia is consisting of a mixture between civil law, sharia, and customary law, that's it. I hope anyone can edit this article and add indonesia following the respective application. the end. correct me if i am wrong. 2404:8000:1027:85F6:1193:21A2:D1B3:FBAD ( talk) 11:02, 16 May 2023 (UTC)