<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> Social </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, UK (except Scotland), India, Cyprus, Nigeria, Ireland, Singapore, Hong Kong, USA (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), Congo, Azerbaijan, Kuwait, Iraq, Russia, Turkey, Egypt, Madagascar, Lebanon, Switzerland, Indonesia, Vietnam, Thailand </Td> <Td> Soviet Union, China, Cuba </Td> <Td> Many Muslim countries have adopted parts of Sharia Law . Examples include Saudi Arabia, Afghanistan, Iran, UAE, Oman, Sudan, Malaysia, Pakistan and Yemen . </Td> </Tr> </Table> <Tr> <Th> </Th> <Th> Common law </Th> <Th> Civil law </Th> <Th> Socialist law </Th> <Th> Islamic law </Th> </Tr>

Difference between french civil law and english common law
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