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.

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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	Germany	France
Legal family	Civil law	Civil law
JuriGlobe lists	Civil law	Civil law
In short	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.	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.
Where the law comes from	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 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 main courts	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	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
Becoming a lawyer	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 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.
What may surprise you	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.	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.
Related systems	France, Bulgaria, Japan, Russia, United States	Germany, Bulgaria, Canada, Japan, Russia

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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.