Main legal systems of the world
Law is not separate from the culture, history and times in which it exists. The study of law is not limited to learning legal rules. The study of law is the study of a people, a civilization, as it currently exists. As a discipline, the law it is also a series of concepts and rules that shifts to meet social changes. Understanding the legal environment of business, therefore, requires a broad understanding of the people and basic trends that influence the relationship between law and business.
In the age of the internationalization and globalization of the world economy, law and business are inextricably intertwined. Business is the organization of capital and labor to produce a product or service with every aspect of that organization regulated by law. It should be noted that the law has often been described as „a seamless web” in which principles of the law are hopelessly intertwined with each other. For this reason, any attempted classification or description of the many and varied legal subjects is necessarily inaccurate.
The word „law” has many meanings, and it is used in many disciplines. In physics the is the law of gravity, in economics there is the law of supply and demand. Even if the field of jurisprudence – which is the scientific study of the law – scholars have offered dozens of different definitions of law. Generally speaking, no word of such common usage is so hard to define precisely or is used to express a variety of concepts as is the word „law”.
Law has also been defined as the body of principles and rules which the courts apply in the decision of controversies. Law is made up of three elements:
- formulated legislation, including constitutions, statutes, treaties, ordinances and codes;
- rules of law announced by the courts in deciding cases; and
- the system of legal concepts and techniques which forms the basis of judicial action.
However, for purposes of this text, the term „law” denotes the body of rules and regulations that is the product of the lawmaking process. Since business, social and political relationships are changing daily, a flexible legal systems is needed to accommodate the new and unprecedented problems that are constantly arising. Therefore, it is important to view law as a dynamic and evolving system of social control and not as an unchanging body of „dos and don’ts”. Finally, the law may be seen as a mechanism for adjusting claims of conflicting rights.
The total body of law by which we are governed comes sources of law. Sources of law are the materials and processes out of which law is developed. In modern nation states, the sources of law either comes from the written law or the unwritten law. Constitution, statutes, case law and regulations issued by government institutions. Sources of law for public international law and religious law differ, however, from the primary law of individual countries. The natural law theory argues that some rules objectively existing in the nature also are source of law, while legal positivism argues that only the rules made by sovereignty can be the source of law.
It should be noted that there are three main sources of the law in the world. They are:
- legislation (it includes constitution and statutes which are prepared by Parliament),
- case law or decisions of the higher court,
- customary law or custom.
What is important to note is that the four major legal systems of the world today consist of civil law, common law, customary law and religious law. Though the systems differ in the contents of their law and the institutions and professions which surround them, the indigenous sources of laws are in fact similar in all four jurisdictions. However, each country often develops variations on each system or incorporates many other features into the system.
It should be remembered also that European Laws from European Union (and in the future perhaps, the European Convention on Human Rights) are also source of law.
Categorizations of legal systems of the world.
It should be noted that the legal system is a system for interpreting and enforcing the laws, in other words it is a legal regimen of a country consisting of:
- a written or a real constitution,
- primary legislation (statutes) enacted by the legislative body established by the constitution,
- subsidiary legislation (bylaws) made by persons or bodies authorized by the primary legislation to do so,
- customs applied by the courts on the basis of traditional practices, and
- principles or practices of civil, common, Roman, religious or other code of law.
In order to clear the ground for the consideration of the more interesting concepts connected with the categorizations of the main legal systems, it is desiderable in the first instance to define the general meaning of the term: comparative law, as the instrument of analysis of differences and similarities between the law of different countries.
What is meant by comparative law?
In the strict sense, it is the theoretical study of legal systems by comparison with each other, and has a tradition going back over a century, although the birth of modern comparative law is generally attributed to Europe in the eighteenth century. According to the prevalent view, Montesquieu1 is regarded as the „father” of comparative law. His comparative approach is obvious in the following excerpt from Chapter III of Book I of what many consider to be his masterpiece, „De l’esprit des lois”.
„The law of nations is naturally founded on this principle, that different nations ought in time of peace to do one another all the good they can and in the time of war was little injury as possible, without prejudicing their real interests (…)”2
„They3 should be adapted in such a manner to the people for whom the are framed that it should be a great chance if those of one nation suit another.
They should be in relation to the nature and principle of each government: whether they support it, as in the case of civil institutions.
They should be in relation to the climate of each country, to the quality of its soil, to its situation and extent, to the principal occupation of the natives, whether husbandmen, huntsmen or shepherds: they should have relation to the degree of liberty which the constitution will bear; to the religion of the inhabitants, to their inclinations, riches, numbers, commerce, manners, and customs (…)”.
Also in Chapter XI ( entitled: „How to compare two different Systems of Laws”) of Book XXIX (Of the Manner of Composing Laws) he states that:
„In France the punishment for false witnesses is capital; in England it is not (…)”, and advise that:
„Wherefore, to determine which of those systems is most agreeable to reason, we must take them each as a whole and compare them in their entirety”.
Yet another excerpt where Montesquieu’s comparative approach is evident, is the following one from Chapter XIII (entitled: „That we must not separate Laws from the End for which they were made: of the Roman laws on Theft”) of Book XXIX:
„As the civil laws depend on the political institutions , because they are made for the same society, whenever there is a design of adopting the civil law of another nation, it would be proper to examine beforehand whether they have both the same institutions and the same political law”.
In this context, it should be added, however, that the comparative law was really born of the ashes of WW II, brought to America by a legal scholar fleeing persecution in Germany, Rudolf Schlesinger4.
The purposes of comparative law is an academic study of separate legal systems, each one analyzed in its constitutive elements, i:e. how they differ in the different legal systems, and how their elements combine into a system5. Several disciplines have developed as separate branches of comparative law, including:
- comparative constitutional law,
- comparative administrative law,
- comparative civil law (in the sense of the law of torts, delicts, contracts and obligations),
- comparative commercial law (in the sense of business organizations and trade), and
- comparative criminal law
Studies of these specific areas may be viewed as micro- or macro comparative legal analysis, i.e. detailed comparisons of two countries, or broad-ranging studies of several countries. Comparative civil law studies, for instance, show how the law of private relations is organized, interpreted and used in different systems or countries.
It should be noted, however, that comparative law is different from the fields of general jurisprudence (legal theory), international law, including both public international law and private international law (also known as conflict of laws). Despite the differences between comparative law and these other legal fields, comparative law helps inform all of these areas of normativity6.
It is clear that comparative law is a very important discipline in communication between legal systems. In recent years it has gained in practical importance for two reasons.
The first is the increase globalization of world trade, involving the need to „do business” in unfamiliar legal systems. In this globalizing world, comparative law is important for it provides a platform for intellectual exchange in terms of law and it cultivates a culture of understanding in a diverse world7.
The second is the move towards harmonization of laws, and more recently towards codification, e.g., within the European Union, where several legal traditions coexist. Furthermore, comparative law helps in broadening horizons for law reformers and legislators around the world. It can also be helpful in international relations in shaping foreign policies8.
Wee turn now to the problem which this subchapter discusses, namely to classifications of legal systems.
Among the many different propositions of the categorizations of legal systems in the world, the most important are the following classifications:
- Classification of legal system into seven groups (so-called „families”), in particular:9
- The French group, under which are included the countries that codified their law either in 19th or in the first half of 20th century, using the Napoleonic code civil of year 1804 as a model; this includes countries and jurisdictions such as Italy, Portugal, Spain, U.S. state of Louisiana, states of South America (such as Brazil), the province of Quebec, Santa Lucia, Romania, the Ionian Islands, Egypt, Lebanon, etc.;
- The German group;
- The Scandinavian group (comprising the laws of Sweden, Norway, Denmark, Finland and Iceland);
- The English group (incl. England, the United States, Canada, Australia and New Zealand inter alia);
- The Russian group;
- The Islamic group (used in the Muslim world);
- The Hindu group.
- Classification of legal systems, according to the different ideology inspired each one, into five groups of families:10
- Western Laws11, a group subdivided into the:
- Romano-Germanic subgroup (comprising those legal systems where legal science was formulated according to Roman Law (see also: Civil Law));
- Anglo-Saxon subgroup.
- Soviet Law12
- Muslim Law13
- Hindu Law14
- Chinese Law15
- Western Laws11, a group subdivided into the:
However, the most important classification of the legal systems of the world is following categorization:
- civil law,
- common law,
- religious law,
- socialist law,
- customary law,
- mixed law.
It should be noted that the two first types of law, i.e. civil law and common law, are the most widespread systems of law in the world, but their particular characteristics is presented in subchapter 1.1.3.
Religious law is seen as a branch of comparative and legal study. Further, it is argued here that comparative law itself may most usefully be seen as part of the tradition of legal philosophy. Far from being wholly academic, however, comparative law is a practical approach in the service of:
- legal education,
- the appreciation of treaty implementation, and
- choice of law in the new world of public/private international law known as transnational law.
How are we to explicate the notion of a religious legal system?
We cannot do so by referring to particular legal system (canon law, for example) as the paradigm case of a religious legal system, for the simple reason that no legal system is self-evidently religious. The designation „religious system” cannot be read off nature but is the product of human reflection. Characterization of a legal system as religious law is always based on assessing whether it fulfils conditions we ourselves have stipulated. The stipulation that certain features are constitutive of religious systems is in turn anchored in an intuitive distinction between religious and non-religious systems. The theoretical notion of a religious legal system is the product of critical analysis, and while its must preserve the pre-analytic intuition in some sense, the overlap need not be complete16.
Generally speaking, the concept of a religious legal system is a cluster concept it is defined by several traits, not all of which need apply simultaneously. This generates a continuum. At one pole is the class of religious systems proper: those with all the traits of religious systems, at the other pole is a class of non-religious systems proper, with none of the said traits. In other words, both poles are likely to be empty classes: no existing legal system has or lacks all the traits in question. Actual legal systems are located on the continuum somewhere in between the two poles. A legal system’s religiosity is determined by its proximity or remoteness from one of the poles17. Note that we usually conceive of as secular systems also exhibit some traits of religious legal systems, and vice-versa.
It should be noted that there are four types of relationships between religious systems and legal systems. At one end of the spectrum is the religious system predominating over the legal system, called a theocracy. At the other end of the spectrum is the legal system dominating over the religious system, behavior typical of communist regimes, for example. In between the two ends of the spectrum of relationship-types, there are many different coexistence relationships between the two systems, which involve constitutional or voluntary separation of the two coexisting systems.
Religious law refers to the concept of a religious system or document being used as a legal resource, refers to the concept that the word of God is law. The use of religion for public law has a static and permanent quality, preventing improvement during legislative acts of government or development during judicial antecedent.
The most important kinds of religious law are Halakha in Judaism, Shari’ah in Islam, both of which denote the „path of follow”, and Canon law in Roman Catholic Church. In some cases these are proposed simply as individual moral guidance whereas in other cases these are proposed and may be used as the source for country’s legal system.
The Halakha is followed by traditional and conservation Jews in both ecclesiastical and civil relations. No country is completely governed by Halakha, but two Jewish people may decide, because of personal belief, to have an argument heard by a Jewish court, and be limit by its rulings18.
Shari’ah law governs some number of Islamic countries (Sunni and Shia), counting Saudi Africa and Iran, although most countries uses Shari’ah law as a complement to national law. It can refer to all characteristics of civil law, including property rights , contracts or public law19.
Canon law is not religious law, appropriately speaking, because it is not found in revelation. Instead, it is seen as human law motivated by the word of God and applying the petitions of that revelation to the actual condition of the Roman Catholic Church20.
According to the Catholic Encyclopedia online via New Advent have the following definitions and description:
„Canon law is the body of laws and regulations made by or adopted by ecclesiastical authority, for the government of the Christian organization and its members… but the expression „canon law” (ins canonicum) becomes current only about the beginning of the twelfth century, being used in contrast with the „civil law” (ins civile), and later we have the „Corpus Iuris Canonici”, as we have the „Corpus Iuris Civilis”. Canon law is also called „ecclesiastical law” (ins ecclesiasticum); however, strictly speaking, there is a slight difference of meaning between the two expressions: cannon law denotes in particular the law of the „Corpus Iuris”, including the regulations borrowed from Roman law; whereas ecclesiastical authorities as such, including those made after the compiling of the „Corpus Iuris”.
In other words, Canon law normalizes the internal ordering of the Roman Catholic Church, the Eastern Orthodox Church and the Anglican Communion. Canon law is rectified and modified by the legislative authority of the Church, such as councils of bishops, single bishops for their respective sees, the Pope for the entire Catholic Church21, and the British Parliament for the Church of England.
Socialist law is the official name of the legal system used in Socialist states. It is based on the civil law system, with major modifications and additions from Marxist-Leninist ideology. While civil law systems have traditionally put great pains in defining the notion of private property, how it may be acquired, transferred or lost, Socialist law systems provide for most property to be owned by the state or by agricultural co-operatives, and having special courts and laws for state enterprises22. Prior to the end of the Cold War, Socialist Law was generally ranked among the major legal systems of the world. However, many contemporary observers no longer consider it to be such, due to similarities with the civil law system and the fact that it is no longer in widespread use (following the dismantling of most communist or socialist states). Furthermore, many scholars argue that socialist law was simply not a separate legal classification23. Although the command economy approach of the socialist states meant that property could not be owned, the Soviet Union always had a civil code, courts that interpreted this civil code, and a civil law approach to legal reasoning (thus, both legal process and legal reasoning were largely analogous to the French or German civil code system)24.
Customary law is generally form custom25, meaning long-established practices that have acquired the force of law by common adoption or acquiescence. It does not vary. Tribal common law is based on the values, mores and norms of a tribe and expressed in its customs, traditions and practices. In some tribes, the tribal common law has been set out in different court decisions and written opinions over time and has become case law.
Customary law is a recognized source of law within jurisdiction of the civil law tradition, inferior to both statutes and regulations. In addressing custom as a source of law within the civil law tradition, it should be clearly indicate, that its importance is slight and decreasing. However, in Canada customary aboriginal law has a constitutional foundation and for this reason has increasing influence. Similarly, in the Scandinavian countries customary law continues to exist and has great influence. It should be added that Customary law is also used in some Thirds World countries, such as in Africa, usually used alongside common or civil law. In law, custom can be described as the established patterns of behavior that can be objectively verified within a particular social setting. A claim can be carried out in defence of „what has always been done and accepted by law”. Generally customary law exists where:
- a certain legal practice is observed, and
- the relevant actors consider it to be law (opinio iuris).
In international law, customary law refers to the Law of Nations or the legal norms that have developed through the customary exchanges between states over time, whether based on diplomacy or aggression. Essentially, legal obligations are believed to arise between states to carry out their affairs consistently with past accepted conduct. These customs can also change based on the acceptance or rejection by states of particular acts. Some principles of customary law have achieved the force of peremptory norms, which cannot be violated or altered except by a norm of comparable strength. These norms are said to gain their strength from universal acceptance, such as the prohibitions against genocide and slavery.
Today, hardly any political entity (country or dependent territory) in the world operates under legal system which could be said to be typically and wholly customary. Custom can take on many guises, depending on whether it is rooted in wisdom born of concrete daily experience or more intellectually based on great spiritual or philosophical traditions. Be that as it may, customary law (as a system, not merely as an accessory to positive law) still plays a sometimes significant role, namely in matters of personal status, in a relatively high number of political entities with mixed legal systems (see below).
Mixed legal systems.
In the website produced at the at the Faculty of Law of the University of Ottawa we may found the following explanation of the term „mixed law”:
The term „mixed” was selected arbitrarily over „hybrid” or „composite”. It should not be understood in the restricted sense but as the category which includes political entities where two or more legal systems apply cumulatively or interactively. It should be clearly indicate that this category also includes entities where there is a juxtaposition of systems as a result of more or less clearly defined fields of application26.
On this concept we have distinguish apart from the five main mono-systems the following classification of mixed, or pluralistic legal systems (see table below).
Table 1. The legal mono-systems and mixed systems of the world
* United Arab Emirates
** The legal system of Vietnam is based on socialist legal theory, French civil law system and on the Confucian law.
*** Bahrain, Qatar, Somalia, Yemen
- E. Örücü, „What is Mixed Legal System: Exclusion or Expansion?”, Electronic Journal of Comparative Law, Vol. 12/1 (May 2008), pp. 1–18,
- C.H. van Rhee, „Mixed legal systems and civil procedure”, 10pp. Remco.email@example.com, (Maastricht University).
It should be noted that the law in Africa is a diverse mix of common law, civil law and religious law systems. Law in Africa has been shaped primarily through different countries inheritance of law which existed in Europe through the nineteenth century. For instance, the primary sources of South Africa legislation were Roman-Dutch and English Common law, imports of Dutch settlements and lawmaking bodies have existed within South Africa over time. As a general rule South Africa follows English Law in the areas of procedural law, law of contract and law of evidence; while Roman Dutch Common law is followed in the South African law of delict (tort), law of persons, law of things, family law, etc.
The sources of South African law are:
- statutory law by the legislative body (the most important of which is the Constitution)
- common law (which includes Roman-Dutch „old authorities and judicial precedent gleaned from case law),
- African customary law, and
- foreign and international law.
The Egyptian judicial system is based on European, primarily French, legal concepts and methods. Under the several governments during the presidency of Hosni Mubarak, the courts have demonstrated increasing independence, and principles of due process and judicial review have gained greater respect. The legal code of Egypt is derived largely from the Napoleonic Code. Marriage and personal status are primarily based on the religious law of the individual concerned. Thus, there are three forms of family law in Egypt: Islamic, Christian, and secular (based on the French family laws).
A polycentric legal system, called Xeer developed exclusively in the Horn of Africa more than millennium ago and is still widely used by the Samali people. Under this system, elders serve as judges and help mediate cases using precedents. Xeer is a good example of how customary law can work in lieu of civil law, and is a good approximation of what is thought of as natural law. Under Xeer, there is no authority that dictates what the law should be. The law is instead discovered by judges as they determine the best way to resolve a dispute. As with law systems in Western states, the Xeer legal system also demands a certain amount of specialization of different functions within the legal framework. Thus, one can find odayal (judges), xeer boggeyaal (jurists), guurtiyaal (detectives), garxajiyall (attorneys), murkhaatiyaal (witnesses) and waranle (police officers) to enforce the law27.
- Charles-Louis de Secondat, Baron de La Brède et de Montesquieu, was born on January 19th, 1689 at La Brède, near Bordeaux, to a noble and prosperous family. Montesquieu’s two most important works are ,,The Persian Letters” and „The Spirit of the Laws” (in a French original: „De l’esprit des Lois”).
- Baron de Montesquieu, „The Spirit of the Laws”, Vol. I, Cosimo, Inc. , New York, 2007, p.5 .
- The political and civil laws of each nation; ibidem, p.6 .
- Rudolf Schlesinger became professor of comparative law at Cornell Law School helping to spread the discipline throughout the United States.
- P. de Cruz, „ A modern approach to comparative law”, Kluwer, Deventer, 1993, 350 pp.
- „Comparative law In the 21st Century” (Edited by A. Harding and E. Örücü, Kluwer Academic Publishers, London-The Hague-New York, 2002 (see: N. Foster, „Transmission and Transferability of Commercial Law in a Globalized World”, p.58–64).
- P.H. Glenn, „Legal Traditions of the World”, Oxford University Press, Oxford, 2000.
- P. Legrand and R. Munday (editors), „Comparative legal studies: traditions and transitions”, Cambridge University Press, Cambridge, 2003 (see: L. Rosen, „Beyond compare”, pp.495–498).
- P. Arminjon, B. Nolde, M. Wolf, „Traité droit comparé”, 3 volumes, Paris, 1950–1952 .
- K. Zweigert. H. Kötz, „Einführung in die Rechtsvergleichung”, Dritte Auflage, Tübingen, Mohr 1996. The comparative analysis of two legal systems is in subchapter 1.1.3.
- The characteristic that he believed uniquely differentiate the Western legal family from other four are: liberal democracy, capitalist economy, Christian religion (see: K. Zweigert. H. Kötz, „Einführung in die Rechtsvergleichung”, op. cit.)
- Soviet law had many of the characteristics of civil law systems, including similar rules of procedure and legal methodologies, although it was distinguishable from other legal systems by the influences of state ownership of the means of production, the power of the Communist Party, the ties between the legal system and national economic planning, the lack of a distinction between civil and criminal law, and the idea that the underlying purpose of the law was to aid in the restructuring of society and advancing towards communism. The legal system of the Soviet Union was the principal model followed by other members of the Soviet Family of legal systems (the countries of eastern Europe, Mongolia, The People’s Republic of China, Cuba and Vietnam being the most notable). This legal system was developed after the Russian Revolution of October 1917 and based on traditional Western civil law, with many elements originating in the Russian legal tradition (going back as far as the 10th Century Kievan Rus) and influenced from Byzantine secular and canon law (see: O.S. Ioffe, „Soviet Law and Soviet Reality”, Martinus Nijholf Publishers, Dordrecht (NL), 1985; „Soviet Law after Stalin”, D.D. Barry, G. Ginsburgs, P.B. Maggs (editors); A.W. Sijthoff International Publishing Company BV, 1977).
- Muslim law is inherently religious. Its principle source is the Qur’an which is considered the final revelation of God to humankind and the ultimate guide to which all practicing Muslims must adhere. The second of the two main primary sources of law (Shari’ah) is the Sunnah (traditions of Muhammad ibn Abdullah; the last prophet of Islam), which means;
- the things he said, i.e. hadith,
- the way he lived his life, his conduct.
The mentioned two primary sources of law, namely the Qur’an and the Sannah, are not only basic textual sources of Islamic law but are also the principal religious texts of Islam. It is important to appreciate the divine origins of both the Qur’an and Sannah in order to understand why and how Islam’s law has developed sophisticated methods of interpretation and law-finding so as to arrive at concrete legal rules capable of solving real legal problems. In addition are the secondary sources of law (the subordinate sources of law) and the methods used to discover and apply the law (Islamic jurisprudence or fiqh), see: M.I. Dien, „Islamic law: from historical foundations to contemporary practice, Edinburgh University Press, Edinburgh, 2004. , W.B. Hallaq, „The origins and evolution of Islamic law”, Cambridge University Press, Cambridge, New York 2005.
- From the ancient time, 2000-1500 B.C., the Vedic literature existed, and while they inform a tradition of gods they point to the concept of the One as interpreted by the Brahmans, these teachers also used the sutras or memorized books (like textbooks) of law or dharma (in one of the meanings; closer to „way of life”).The Laws of Manu, a mythical author, of circa 2000 B.C. shows the beginnings of the legal tradition of great variety although he focus was family, property and succession law. This early Sanskrit literature was replaced gradually in the colonial period when the British substituted their own translations and understanding in place of what came before; Anglo-Indian law preserved family law areas (five elements of familylaw-marriage, child marriage, polygamy, divorce and maintenance) as Hindu personal law and replace the rest with colonial British law. It was a judge made law. The Hindu Code of Independence became one among other personal codes and preserved much of the British innovation. Custom and local tradition could prevail over sacred texts even in time of classical Indian law. According to the Laws of Manu, there are sources of drama:
- the Vedas
- tradition, especially at set forth in treatises like Dharmasastras,
- customary laws created by local or regional communities, and
- personal preference.
(see: W.F. Menski, „Hindu Law: Beyond Tradition and Modernity”, New Delhi, Oxford University Press, 2003;
R. Pal, „The history of Hindu Law in the Vedic age and in post-Vedic times down to the Institutes of Manu”, University of Calcutta, Calcutta, 1958).
- It should be noted that in Marxism, Chinese Law is a part of the superstructure based on and determined by the economic base of the particular society. As above mentioned (see: note 12), in the post-WW II period Chinese law was a part of modified version of the Soviet law model (so called Socialist law). In present Chinese practice, law is intended to serve as means both to consolidate the achievements of economic reform and to promote further such development by way of standardizing and institutionalizing changes in the economic system. In short, law is seen as having to be used to establish stability and order for economic development. The concern for justice and humanity and the protection of basic human rights have taken, and continue to take, a secondary place in determining and propelling legal developments.The direction of economic reform and development is to be decided and guided by the Communist Party policies. Law, though important and necessary, in People’s Republic of China (PRC), is only a tod for implementing Party policies; its character and the extent of development essentially depend on the parameters set by the reform program which has been a pragmatic one ever since Deng Xiaoping took control of China in 1978. To understand legal developments in the PRC, it is therefore important to examine the changes and developments in economic reform policies and their ideological bases and justifications (see also subchapter 1.1.3.).See: J. Chen, „Chinese Law: Towards an Understanding of Chinese Law, Its Nature and Development”, The London-Leiden Series on Law, Administration and Development, Kluwer Law International, Martinus Nijhoff, Dordrecht (NL), 1999.
- P.H. Green, „Legal traditions of the world: sustainable diversity in law”, Oxford University Press, Oxford, New York, 2007.
- J. Goodman, „Divine Judgment: Judicial Review of Religious Legal Systems in India and Israel”, in Hastings International and Comparative Law Review, Vol.32, No.2/2009, p. 481–484
- P.H. Glenn, „Legal traditions of the world …”, op. cit., pp. 93–121
- Ibidem, pp. 171–223.
- J.T. Noonan, et al., „Canons and Canonists in Context”. Publ. Keip, Goldbach, 1997, and R.H. Helmholz, „The Spirit of the Classical Canon Law”, University of Georgia Press, Athens, Georgia, 1996.
- Ecumenical councils of the Church, the Pope and Apostolic Letters such as bulls or briefs, decrees of the Roman Curia or Acts of the Holly See also from part of canon law.
- Commisions (courts) of Arbitration In Poland, for example.
- Ch. Sypnowich, „The Concept of Socialist Law”, Oxford University Press, New York, 2002, (second edition), pp.139–143.
- See note 12 (Soviet law) and 15 (Chinese Law)
- See „Constumes de beavoisis”, par Philippes de Beaumanoir et etc., Paris 1690, pp.824, (in title of French original is used archaic form: „Coustumes” instead of „Coutumes”, i.e., in English
- See: http://aix1.uottawa.ca/world-legal-systems/eng-systems.html.
- „Back to Somali roots”, http://www.hiiraan.com/op2/2008/oct/ack_to_somali_roots.aspx