China

• The Constitution, and the basic laws passed by the National People's Congress and its Standing Committee
• The Civil Code (in force from 2021) and other codes and statutes
• Judicial interpretations issued by the Supreme People's Court, which explain how courts should apply the law
• Administrative regulations from the State Council and local rules

• The Supreme People's Court at the top
• High People's Courts, then Intermediate People's Courts, then Basic People's Courts
• The Supreme People's Procuratorate, a separate body that prosecutes and supervises legality

A law degree (or equivalent), then the unified national legal professional qualification examination, then practical training and a licence. Judges and prosecutors qualify under the same national exam.

• The Standing Committee of the National People's Congress, not the courts, has the final say on the meaning of laws.
• The Supreme People's Court issues 'judicial interpretations' that work almost like legislation.
• There is no judicial review of laws by courts in the Western sense.
• Under 'one country, two systems', Hong Kong is a common-law jurisdiction and Macau is a civil-law one, each with its own courts.

Japan, Russia, Germany, France, Bulgaria

The University of Ottawa’s JuriGlobe database lists China as: Civil law, Customary. It names the systems in order of importance.

The map colours a country by the first-named system, and shows both civil-law and common-law countries as “mixed”. It is a simplification, and real systems are rarely pure.

Albania, Algeria, Angola, Argentina, Armenia, Austria, Azerbaijan, Belarus, Belgium, Benin, Bolivia, Bosnia and Herzegovina, Brazil, Bulgaria.

• Supreme People's Court (English pages)
• Federal Judicial Center: China
• Supreme People's Court Monitor: the Civil Code and the Supreme People's Court

Sources last reviewed: October 2026.