Legal system

[7] Under Austin's analysis, any law that is part of a legal system must have been enacted by the same sovereign legislator.

Hart argued instead that each legal system is defined by a shared rule of recognition under which a pronouncement is recognized as valid law.

[15] The origin of this view of international law is credited to the 18th-century German legal theorist Georg Friedrich von Martens.

[16] Various different taxonomies of legal systems have been proposed, for example into families or traditions on historic and stylistic grounds.

[19] Classifications of legal systems have often reflected the classifier's view of geopolitical power relations.

In 1909, Adhémar Esmein proposed classifying legal systems into Roman, Germanic, Anglo-Saxon, Slavic, and Islamic groups, which corresponded to the five major global empires of the time.

[20] This classification ignored, among others, the legal systems of Africa, China, and Japan, which Esmein did not consider significant.

[21] In 1913, Georges Sauser-Hall proposed an explicitly racial classification of legal systems into Indo-European, Semitic, and Mongolian.

[22] In 1928, the American scholar John Henry Wigmore proposed a five-part classification of legal systems: primitive, ancient, Euro-American, religious, and "Afro-Asian".

[27] In 1973, German comparatists Konrad Zweigert and Hein Kötz proposed a similar classification that recognized "Romanist" (typified by France), "Germanic", Anglo-American, Scandinavian, Socialist, Hindu, Islamic, and "Far Eastern" groups of legal systems, which were all distinguished from one another on stylistic grounds.

[28] Until the 1990s, these classifications of legal systems into family groups were typically considered rigid and fixed over time.

For example, the World Justice Project ranks national legal systems annually by their adherence to the rule of law.