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.

JapanGermany

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	Japan	Germany
Legal family	Civil law	Civil law
JuriGlobe lists	Civil law, Customary	Civil law
In short	Japan has a civil-law system built in the late 1800s on German and French models, and reshaped after 1945 under a new constitution that includes judicial review. Courts apply the codes, and many disputes are settled by mediation.	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.
Where the law comes from	The Constitution of 1947, the highest law The main codes: the Civil Code, the Commercial Code, the Criminal Code and the two procedure codes Statutes passed by the National Diet (the parliament) Court decisions, especially from the Supreme Court, which guide lower courts in practice	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 main courts	The Supreme Court at the top High Courts (several regional ones, plus a specialised Intellectual Property High Court) District Courts, Family Courts and Summary Courts at the first level	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
Becoming a lawyer	A law degree and a national bar examination, then a period of training at the Legal Training and Research Institute run by the Supreme Court. Future judges, prosecutors and attorneys all train there together.	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.
What may surprise you	Future judges, prosecutors and attorneys train together, which is unusual. Since 2009, ordinary citizens sit with professional judges as lay judges in serious criminal cases. Japan has relatively few lawyers and few lawsuits, and conciliation and mediation are very common. Japan's codes have a German structure, so German legal ideas are a good way to understand Japanese private law.	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.
Related systems	Germany, France, China, Bulgaria, Russia	France, Bulgaria, Japan, Russia, United States

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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.