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.

SingaporeHong KongAustralia

Choose two to 5 countries.

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

Topic	Singapore	Hong Kong	Australia
Legal family	Common law	Common law	Common law
JuriGlobe lists	Common law, Muslim	Common law, Customary	Common law
In short	Singapore is a common-law country. It inherited English law, and its courts today use a mix of English and local decisions. It has a written Constitution and a separate Syariah Court for Muslim family law.	Hong Kong is a common-law jurisdiction inside China. Under the principle of 'one country, two systems' and its Basic Law, Hong Kong keeps its own legal system, with its own courts and the common law it inherited from England.	Australia is a common-law country and a federation. Its law comes from the Constitution of 1901, from federal and state statutes, and from judges' decisions. The High Court of Australia is the final court of appeal.
Where the law comes from	The Constitution of Singapore, the highest law Acts of Parliament Case law (precedent), from Singapore and other common-law countries Muslim law, for Muslim family matters	The Basic Law of Hong Kong, which works as its constitution Ordinances passed by the Legislative Council Common law and equity, developed by the courts Customary law, in limited matters such as certain land and succession rules	The Commonwealth Constitution of 1901, which divides power between the federal government and the states Acts of the federal Parliament and of the state and territory parliaments Case law (precedent), including the High Court's decisions on both state and federal law Native title, recognised by the High Court in the Mabo case (1992)
The main courts	The Supreme Court: the Court of Appeal and the High Court State Courts for smaller civil and criminal cases The Syariah Court, for Muslim family matters	The Court of Final Appeal at the top, which may invite judges from other common-law places to sit The High Court (the Court of Appeal and the Court of First Instance) District Court and magistrates' courts below them	The High Court of Australia at the top Federal courts, such as the Federal Court of Australia State and territory courts, each with its own supreme court, which hear most cases
Becoming a lawyer	A law degree from an approved university, a bar course (Part B), and a practice training period, followed by admission by the Supreme Court. Lawyers from some abroad can take a separate qualifying route.	The profession is split into barristers and solicitors. Lawyers qualified abroad can take the Overseas Lawyers Qualification Examination (OLQE) to become solicitors.	A law degree covering the required core subjects (often called the Priestley 11), then practical legal training, then admission by the Supreme Court of a state or territory. In some states barristers and solicitors are separate, and in others they are not.
What may surprise you	Singapore ended appeals to the Privy Council in 1994, so the Court of Appeal now has the last word. Courts follow English cases but are free to depart from them. The legal profession is united: advocates and solicitors. Commercial courts and arbitration are central to Singapore's role as a regional dispute-resolution hub.	A common-law system sits inside a country whose mainland system is civil law. The Basic Law is interpreted in the end by the Standing Committee of China's National People's Congress. English and Chinese are both official languages in the courts. The system's rules and institutions have changed in recent years, so check current developments.	Australia has no national bill of rights in its Constitution, only a few specific protections. There is one common law for the whole country: the High Court decides common-law questions for all states. Admission is by state, but can be recognised across the country. Australian and English law share many roots, but Australian courts no longer follow every English development.
Related systems	United Kingdom, India, Hong Kong, Australia, Malaysia	United Kingdom, Singapore, China, Australia, India	United Kingdom, Canada, United States, Ireland, India

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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.