Comparison between legal system of Bangladesh, U.K, U.S.

Legal system of each country is different from others. Some legal system is based on written

constitution; some are based on unwritten ones. Comparative law means discuss between

differences and similarities between the law of different countries. This study is about the

comparison between legal systems of different countries. Three countries have been

compared here.

Bangladesh Legal System:

Bangladesh is a common law based jurisdiction. Many of basic laws of Bangladesh such as

penal code, civil, criminal procedures codes, contract law and company law are influenced by

English common laws. Family laws are relating to marriage, dissolution of marriage and

inheritance are based on religious scripts and therefore religious committees.

Bangladesh legal system based on a written constitution and laws are often taken from

statutory form which are exacted by the legislature and interpreted by higher courts.

Bangladesh does not have any jury system. But (sec- 15, 19) of crape empower magistrates.

The high court division of the country also operates. In Bangladesh rule of law has not been

established yet though (Art. 27) of constitution states all citizens are equal before law and

entitled to equal protection of law.

In Bangladesh there is the system of passing capital punishment or death penalty though its

avoided in developed country.

U.S.A Legal System:

In U.S.A there is federal system of government; legal system is based on written constitution

though the term is used as convenience. In U.S.A there is a federal government, different

legal system for each fifty states.

U.S.A constitution provides the right of a jury trial. The judge is one who keeps control in the

court.

There are three types of jury. In U.S.A there is “separation of power” and check and balance.

UK Legal System:

Sub-nationally, the United Kingdom has three legal systems, each of which derives from a

particular geographical area and for a variety of historical reasons: English law, Scots law

and Northern Ireland law.

U.K doesn’t have any written constitution. It’s made up for four main parts.

Statute Law

Common Law

Convention Law

Work of authority

Ensuring rule of law:

Rule of law has great importance and very important feature of British Constitution. No one

can escape beyond judicial capacity. In case of passing any sentence regarding any criminal

ease U.K. proves its intelligence. They prefer pecuniary compensation rather than custodial

sentences. U.K avoid death penalty, they are more awake sono injustice would done.

In United Kingdom there is jury system. They have adopted juries Act 1974 for determining

procedure.