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A CLOSE look at the laws of the Asean countries would readily reveal the intricate mosaic of legal systems in existence in the region. It is not simply a choice between common law or civil law or a mixture of both. While one system is founded on Islamic or Hindu law, a few others share traditions of British law superimposed upon Islamic foundations, modified by modern indigenous legal innovations. Others have indigenized eclectic legal systems which have integrated concepts from American, Spanish, Indian and French legal systems. Intricate as it is, the mosaic is even more elaborate when seen in detail, with a great variety of ethnic and customary law.

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