Compare legal systems

Put two to five countries side by side, or compare whole legal families. Germany next to France, or the United States next to India, shows quickly what the two share and where they part ways.

FranceGermanyItalySpain

Choose two to 5 countries.

All of these are in the same legal family (Civil law), so look at the differences in courts, training and the details below.

Topic	France	Germany	Italy	Spain
Legal family	Civil law	Civil law	Civil law	Civil law
JuriGlobe lists	Civil law	Civil law	Civil law	Civil law
In short	France is the model civil-law country. Its Civil Code of 1804, written under Napoleon, shaped the law of much of Europe, Latin America and Africa. France also splits its courts in two: ordinary courts for private and criminal cases, and administrative courts for disputes with the state.	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.	Italy is a civil-law country with a Constitution of 1948 and a Civil Code of 1942 that covers both civil and commercial law. Its Constitutional Court is the guardian of the Constitution, and judges and prosecutors belong to one judicial career.	Spain is a civil-law country with a Constitution of 1978 and a Civil Code of 1889. Some regions have their own civil law traditions, and Spain's courts apply European Union law as well.
Where the law comes from	The Constitution of 1958 and the principles in its preamble Codes and statutes, such as the Civil Code, the Criminal Code and the Commercial Code European Union law, which takes priority in its area Court decisions (jurisprudence) and scholars' writing (doctrine), which are persuasive and influential but not formally binding precedent	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	The Constitution of 1948, the highest law The Civil Code (1942), the Penal Code and other codes and statutes European Union law, which takes priority in its area Court decisions (giurisprudenza), which are very important in practice, and scholarly writing	The Constitution of 1978, the highest law National codes and statutes, such as the Civil Code and the Penal Code, and regional laws in the autonomous communities European Union law, which takes priority in its area Case law of the Supreme Court, which supplements the statutes
The main courts	Ordinary (judicial) courts: the Court of Cassation at the top, then courts of appeal, then first-instance courts Administrative courts: the Council of State (Conseil d'État) at the top, with administrative courts of appeal and first-instance administrative courts The Constitutional Council (Conseil constitutionnel), which checks laws against 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	The Court of Cassation (Corte di Cassazione) at the top of the ordinary courts The Constitutional Court, which reviews laws, and the Council of State for administrative cases Courts of appeal and first-instance courts, with justices of the peace for small matters	The Supreme Court (Tribunal Supremo) at the top of the ordinary courts The Constitutional Court, which reviews laws and hears individual constitutional complaints (recurso de amparo) National High Court, regional high courts, provincial courts and first-instance courts
Becoming a lawyer	A law degree and a master's, then an entrance exam and a year or more of professional training at a lawyers' school, then the title of avocat. Judges are trained separately at the National School for the Judiciary.	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.	A five-year law degree, a period of practical training, and a state examination, followed by registration with a local bar council.	A law degree and a master's degree for the legal profession, practical training, and a state examination, followed by registration in a bar association (colegio de abogados).
What may surprise you	Two top courts: one for private and criminal law, one for disputes with the state. Judges are not strictly bound by earlier decisions, though in practice the top courts' decisions are followed. The Court of Cassation's judgments have traditionally been short and formal, though they now explain more than they used to. Scholars (the 'doctrine') have real influence on how the code is understood.	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.	Judges and public prosecutors share a common judicial career (the magistratura) and can move between the two roles. The Civil Code includes commercial and company law, so there is no separate Commercial Code. The Constitutional Court decides on questions referred to it by ordinary judges, not just direct challenges. Italian law strongly influenced other civil-law systems through its Roman-law scholarship.	Some regions, such as Catalonia and Aragon, have their own civil laws in addition to the national Civil Code. Citizens can bring an individual constitutional complaint to the Constitutional Court once ordinary remedies are exhausted. Spanish law has been a model for most of Latin America. Court decisions are not formal precedent, but repeated Supreme Court rulings are followed in practice.
Related systems	Germany, Bulgaria, Canada, Japan, Russia	France, Bulgaria, Japan, Russia, United States	Spain, France, Germany, Argentina, Brazil	Italy, France, Mexico, Argentina, Brazil

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An educational overview that simplifies on purpose. It is not legal advice. For a real legal question, consult a lawyer qualified in the country concerned.