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Outside of the UK and Ireland (Malta and Cyprus having a mixed system), all other European countries operate a Civil law system.

As a supranational law European Union law has direct and indirect effect in the EU Member States (currently 27 European countries). It is based on the EU Treaties which regulate that some provisions apply directly (e.g. Regulations) and some have to be implemented in the Member States’ national law within a pre-defined period of time (ie Directives).

The law in Africa contrasts common law, customary law, civil law and religious legal systems. It has been shaped by European law. For example, the South African legal system is based largely on Dutch law and English Common law.

Australia operates on a common law system. All States and territories of Australia that are self-governing are separate jurisdictions with their own courts and parliaments. The systems of laws in each state are influential on each other, but not binding. Laws passed by the Parliament of Australia apply to the whole of Australia.

Chinese law is derived from the German system and adopts civil law. This was adopted following the Revolution of 1911. The establishment of the People's Republic of China in 1949 led to the adoption of a Soviet-influenced system of socialist law.

The present legal system of the People's Republic of China began developing in the late 1970's. In recent years, China has begun to adopt some principles and institutions along the lines of a common law system.

Hong Kong’s legal system is based on common law principles and statute. It resembles closely the law of England and Wales.

Japan has a civil law system which is based on Germany’s legal system. The legal market is centred in Tokyo, also the location for Japan’s highest court, the Supreme Court.

Singapore follows a common law system based on the English system. Key areas of law – particularly administrative law, contract law, equity and trust law, property law and tort law – are largely judge-made, though certain aspects have now been modified to some extent by statutes.

The legal system in India is largely based on English common law. During the drafting of the Indian Constitution, laws from Ireland, the United States, Britain, and France were synthesized to create a bespoke set of Indian laws.

The law of Malaysia is mainly based on the common law legal system. The supreme law of the land is the Constitution of Malaysia. Federal laws are enacted by a Parliament with Legislative Assemblies legislating for particular states.

The Philippines operates a civil law system and adopts the system of codification of laws which is common to countries governed by civil law.

New Zealand follows a common law system. The primary sources of New Zealand law are statutes enacted by the New Zealand Parliament and decisions of the New Zealand Courts. At a more fundamental level, the law of New Zealand is based on three related principles: parliamentary sovereignty; the rule of law; and the separation of powers.

The law of the United States consists of many levels of codified and uncodified forms of law, of which the most important is the United States Constitution, the foundation of the federal government of the United States. The Constitution sets out the boundaries of federal law, which consists of constitutional acts of Congress, constitutional treaties ratified by Congress, constitutional regulations promulgated by the executive branch, and case law originating from the federal judiciary.

The Canadian legal system has its foundation in the British common law system with the exception of Quebec where a civil system is retained for issues of private law. Both legal systems are subject to the Constitution of Canada.

UAE

Member of the GCC – with civil law which was based on Egyptian law but inspired by Sharia concepts. Has separate national level Federal Law – and law of the 7 individual Emirates which include Dubai, Abu Dhabi and Sharjah. There is some left over legislation from the time of the British protectorate in the 1940/50s originally published in the Persian Gulf Gazette. Within the UAE there are also numerous freezones including the DIFC – which have their own legislative system based on commonwealth and courts run by a mixture of commonwealth and local judges.

Qatar

Important financial centre. Member of the GCC – with civil law based on Egyptian law but inspired by Sharia concepts. Includes a well-known freezone – called the QFC which uses an adaption of commonwealth law and has courts run by a mixture of commonwealth and local judges. QFC cases are enforceable in Qatar and the QFC courts offer themselves as a location for international commercial disputes. We have coverage of the business laws of this jurisdiction, the free zone cases and legislation – and are currently building a full set of legislation.

Saudi Arabia

Member of the GCC but with a Sharia based system. In recent years has set up industrial zones.

Oman

Member of the GCC but less financially developed than the other states – has civil law based on Egyptian law but inspired by Sharia concepts. There is some left over legislation from the time of the British protectorate in the 1940/50s originally published in the Persian Gulf Gazette.

Kuwait

Member of the GCC but less financially developed than the other states – has civil law based on Egyptian law but inspired by Sharia concepts. There is some left over legislation from the time of the British protectorate in the 1940/50s originally published in the Persian Gulf Gazette.

Bahrain

Member of the GCC – and an active financial services centre. Whereas other gulf states are using the commonwealth law arbitration model, it has tied up with the American AAA and is using its arbitration model to market itself as an arbitration freezone. Cases at its international arbitration centre – can also be heard under Bahrain law and ratified by the Bahrain courts – which helps make them recognised in other GCC states. There is some left over legislation from the time of the British protectorate in the 1940/50s originally published in the Persian Gulf Gazette

Egypt

Civil legislation inspired by Sharia – commentary from this jurisdiction is particularly important as most GCC countries copied the Egyptian codes and put them into their legislation – and Egyptian judges work in GCC courts. Also has an active international arbitration centre – which has maintained its business through recent political problems. At present political unrest has disrupted the legislative process – and many earlier laws are being cancelled.

Lebanon

Highly developed civil legislation – following the code format. Many local lawyers are trained in France – and terminology, legal concepts etc in Lebanese law often come from French law.