The second category groups together those Muslim countries whose legal system is patterned on the continental European legal systems, namely, the Romaniuic (French) legal system and the Germanic (German and Swiss) legal system but in particular that of France.

The laws based on the Sahri’ah in these countries are confined to the fleld of family law and personal status.

There are some eighteen countries which fall into this category. These are: Algeria, Burkina Faso, Chad, Djibouti, Egypt, Guinea, Iraq, Kuwait, Jordan, Lebanon, Libya, Mali, Morocco, Niger, Senegal, Syria, Tunisia and Turkey.

Libya, however, is, or at least claims to be, moving towards what has been termed “Islamic socialism”.

ADVERTISEMENTS:

The third category includes those Muslim countries whose legal system is basically based on the Anglo-American legal family, but in particular the English common law.

The influence of the Sharia based laws is again confined to areas of personal status, family and inheritance of the Muslims. These countries are: Pakistan, Bangladesh, Malaysia, Sudan, Nigeria and the Gambia.

“.