<P> Some authors consider civil law the foundation for socialist law used in communist countries, which in this view would basically be civil law with the addition of Marxist - Leninist ideas . Even if this is so, civil law was generally the legal system in place before the rise of socialist law, and some Eastern European countries reverted to the pre-Socialist civil law following the fall of socialism, while others continued using a socialist legal systems . </P> <P> Several civil - law mechanisms seem to have been borrowed from medieval Islamic Sharia and fiqh . For example, the Islamic hawala (hundi) underlies the avallo of Italian law and the aval of French and Spanish law . </P> <P> The table below contains essential disparities (and in some cases similarities) between the world's four major legal systems . </P> <Table> <Tr> <Th> </Th> <Th> Common law </Th> <Th> Civil law </Th> <Th> Socialist law </Th> <Th> Islamic law </Th> </Tr> <Tr> <Td> Other names </Td> <Td> Anglo - American, English, judge - made, legislation from the bench </Td> <Td> Continental, Romano - Germanic </Td> <Td> Soviet </Td> <Td> Religious law, Sharia </Td> </Tr> <Tr> <Td> Source of law </Td> <Td> Case law, statutes / legislation </Td> <Td> Statutes / legislation </Td> <Td> Statutes / legislation </Td> <Td> Religious documents </Td> </Tr> <Tr> <Td> Lawyers </Td> <Td> Judges act as impartial referees; lawyers are responsible for presenting the case </Td> <Td> Judges dominate trials </Td> <Td> Judges dominate trials </Td> <Td> Secondary role </Td> </Tr> <Tr> <Td> Judges' qualifications </Td> <Td> Career lawyers (appointed or elected) </Td> <Td> Career judges </Td> <Td> Career bureaucrats, Party members </Td> <Td> Religious as well as legal training </Td> </Tr> <Tr> <Td> Degree of judicial independence </Td> <Td> High </Td> <Td> High; separate from the executive and the legislative branches of government </Td> <Td> Very limited </Td> <Td> Ranges from very limited to high </Td> </Tr> <Tr> <Td> Juries </Td> <Td> Provided at trial level </Td> <Td> May adjudicate in conjunction with judges in serious criminal matters </Td> <Td> Often used at lowest level </Td> <Td> Allowed in Maliki school, not allowed in other schools </Td> </Tr> <Tr> <Td> Policy - making role </Td> <Td> Courts share in balancing power </Td> <Td> Courts have equal but separate power </Td> <Td> Courts are subordinate to the legislature </Td> <Td> Courts and other government branches are theoretically subordinate to the Shari'a . In practice, courts historically made the Shari'a, while today, the religious courts are generally subordinate to the executive . </Td> </Tr> <Tr> <Td> Examples </Td> <Td> Australia, United Kingdom (except Scotland), India, Cyprus, Nigeria, Republic of Ireland, Singapore, Hong Kong, United States (except Louisiana), Canada (except Quebec), New Zealand, Pakistan, Malaysia, Bangladesh </Td> <Td> All European Union states (except the UK, Ireland, and Cyprus) and European states, all of continental South and Middle America (except Guyana and Belize), Quebec, all of East Asia (except Hong Kong), DR Congo, Azerbaijan, Kuwait, Iraq, Russia, Turkey, Egypt, Madagascar, Lebanon, Switzerland, Indonesia, Vietnam, Thailand </Td> <Td> Soviet Union, Law of China, Cuba </Td> <Td> Many Muslim countries have adopted parts of Sharia Law . Examples include Saudi Arabia, Afghanistan, Iran, United Arab Emirates, Oman, Sudan, Malaysia, Pakistan and Yemen . </Td> </Tr> </Table>

What makes civil law different from other types of laws