As lawyers know, authorized systems in international locations around the world generally fall into certainly one of two most important categories: widespread law programs and civil legislation methods. A number of Islamic countries have civil regulation systems that comprise parts of Islamic law 21 For example, the Egyptian Civil Code of 1810 that developed in the early nineteenth century—which remains in pressure in Egypt is the premise for the civil legislation in many international locations of the Arab world where the civil law is used— is predicated on the Napoleonic Code, but its major creator Abd El-Razzak El-Sanhuri attempted to integrate rules and features of Islamic legislation in deference to the unique circumstances of Egyptian society.

eleven See, e.g., French Code of Civil Process Article 1511; Austrian Code of Civil Process s. 603; Belgian Code of Civil Process Article 1710; 2010 UNCITRAL Arbitration Rules Article 35.1; SCC Arbitration Rules Article 27; DIAC Arbitration Guidelines Article 33.1.

Such codes distinguish between totally different classes of regulation: substantive law establishes which acts are subject to criminal or civil prosecution, procedural regulation establishes how one can decide whether or not a particular motion constitutes a felony act, and penal law establishes the suitable penalty.

To the layperson, this may seem to be one other crazy and even ludicrous end result from a jury trial; but from a legal perspective, particularly for attorneys from civil legislation international locations, as are the writers of this entry (China and Colombia), it actually enlarges an ongoing debate.