Each country’s legal system has its own sources of law, with greater weight placed on some sources than others. In developing an infrastructure project, it is important to identify which sources of law apply in the host country and their relative weighting.
Many countries follow one of the two main forms of legal tradition in the world, civil law or common law. The rationale and principles underlying each of these systems are different, although these differences have become less defined over time and some countries have adopted a combination of these systems. The differences may affect how infrastructure project agreements are drafted.
- Common Law System
- Civil Law System
- Civil Law Systems - Key Administrative Jurisprudence that can impact PPP arrangements
For an inexhaustive list of the countries with common law and civil law systems, go to the Legal Systems of the World on Wikipedia