| Legal family | Civil law | Civil law |
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| JuriGlobe lists | Civil law | Civil law |
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| In short | Bulgaria is a civil-law country in the continental European tradition, with strong Roman-law and German influences. Its Constitution of 1991 sets up three powers, and Bulgaria has been a member of the European Union since 2007. | Germany is a civil-law country with a very systematic, conceptual style. Its Civil Code (the BGB), in force since 1900, influenced Japan, Greece and many other countries. Germany is a federation, with sixteen states, and a strong constitutional court. |
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| Where the law comes from | - The Constitution of 1991, the highest law
- Codes and statutes, such as the Law on Obligations and Contracts, the Civil Procedure Code and the Criminal Code
- European Union law, which takes priority in its area, and the European Convention on Human Rights
- Binding interpretations by the Supreme Court of Cassation and the Supreme Administrative Court, which guide the lower courts
| - The Basic Law (Grundgesetz) of 1949, the constitution
- Federal and state statutes and codes, led by the Civil Code (BGB), the Criminal Code and the Commercial Code
- European Union law, which takes priority in its area
- Court decisions and academic commentary, which are highly influential even though they are not formally binding precedent
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| The main courts | - The Supreme Court of Cassation is the top court for civil and criminal cases, and the Supreme Administrative Court is the top court for administrative cases
- Below them: courts of appeal, regional courts and district courts (three levels of review in most cases)
- The Constitutional Court, with twelve judges, checks that laws follow the Constitution
| - Five branches of courts, each with its own top federal court: ordinary (civil and criminal), labour, administrative, social and tax
- The Federal Court of Justice (Bundesgerichtshof) is the top court for civil and criminal cases
- The Federal Constitutional Court (Bundesverfassungsgericht) in Karlsruhe, which can review laws and hear citizens' constitutional complaints
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| Becoming a lawyer | A law degree from a university, then practical training, and admission to a bar association. Judges and prosecutors are chosen and overseen by a Supreme Judicial Council, and the prosecution is part of the judicial system. | A law degree that ends with a first state examination, then about two years of supervised practical training, then a second state examination. A person who passes both is a fully qualified lawyer (a Volljurist) who can become a judge or be admitted as a lawyer. |
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| What may surprise you | - The prosecution service belongs to the judiciary, unlike in the United States or England, where prosecutors are part of the executive.
- A separate set of administrative courts deals with disputes between people and the state.
- As an EU country, Bulgaria's courts apply EU law and can refer questions to the Court of Justice of the European Union.
- Judges give their reasons by applying the code to the facts, rather than discussing earlier cases at length as common-law judges do.
| - The study of law is organised around the state examinations, not the university degree.
- Legal reasoning is highly systematic, working from general concepts down to the case.
- Citizens can bring a constitutional complaint to the Federal Constitutional Court after exhausting other remedies.
- Judges usually work in panels, and written judgments are often very long and structured.
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| Related systems | Germany, France, Russia, Japan, United States | France, Bulgaria, Japan, Russia, United States |
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