dIRItto CLIL - the Main Legal Systems in the World CLIL - THE MAIN LEGAL SYSTEMS IN THE WORLD 181 AUDIO Throughout the world there are two main types of legal systems: Common Law and Civil Law. The two developed in different historical contexts: Civil Law was used in the Roman Empire, while Common Law emerged in England during the Middle Ages. Currently, the main distinction between the two systems is that they have different sources of laws. Common Law is generally uncodified, it does not rely on a set of legal rules and statutes. Civil Law, on the contrary, is codified, and based on a body of comprehensive and continuously updated legal codes. Consequently, Civil Law is based on legislation, while Common Law is based on court decisions and on the concept of judicial precedent (the decisions made by a court are used for future cases). So in Civil Law systems, the judge is an expert of law who must interpret and fill the gaps of the legislative texts, while in Common Law systems he/she has an active role in developing rules. The Civil Law system is the most widespread in the world. Countries following a Civil Law system are typically those that were former French, Dutch, German, Spanish or Portuguese colonies or protectorates, including much of Central and South America. Countries following a Common Law system are typically those that were former British colonies or protectorates, including the United States. 1. Complete the table. Origin Sources of law Role of the judges Diffusion 2. 1. 2. 3. 4. 3. Common Law Civil Law Find the definition for the following words. Code: Court: Judge: Precedent: In the world there are also religious legal systems, where the law emanates from texts or traditions within a given religious tradition. Islamic law (or Sharia law) is the most widespread religious law system, and it governs all aspects of public and private life. Which countries are ruled by religious legal systems?