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xvi | General Introduction they all face: what to do with those who break the law? They have all enacted ei- ther customary or written criminal laws. They have all inherited their criminal laws from their ancestors near and far, not infrequently from other nations that either usurped them or overtook them through migration. They have all devel- oped procedures for the fi nding of guilt of the accused, and all, of course, follow up the fi nding of guilt with legislated or customary punishments. These are all essentially the product of their legal systems. World Legal Systems For more than 1,000 years, the Roman Empire encompassed just about all the region around the Mediterranean and stretched as far north as Great Britain. Law was probably its major weapon against the peoples it subdued, bringing with it order and a stable means of commerce. Its concepts would form much of the basis of canon law and eventually much of the civil law of Europe. Further- more, much of the Islamic and customary law of the countries surrounding the south and east of the Mediterranean was deeply aff ected by Roman law because those peoples were also subjects of the Roman Empire at various times for over 1,000 years. Those countries of Europe that retained more of the Roman law and its procedures would later come to be known as “civil law” countries. Those European countries that managed to put aside Roman law came to be known as “common law” countries. And those of North Africa and the Far East retained Islamic and customary law systems. Civil law systems account for over 50 percent of the world’s legal systems, al- though many such systems are mixed with other legal systems because of local and historical circumstance. In fact, as a result of constant reforms, it is likely that there are no purely civil law systems left in the world. Most countries have incorporated various aspects of the adversarial system. The main characteristics of civil law systems are the following: 1. Systematically written legal codes are the prime source of authority in legal decisions and procedures. 2. Their procedures are often (though not entirely) based on what is some- times called the “inquisitorial system”—reaching back to the days of the Roman Catholic Inquisition—in which the process of fi nding of guilt is conducted by a judge or magistrate who both investigates and conducts the fi nal trial. These trials are usually, though not always, conducted before a magistrate or panel of magistrates. Probably the prime examples of European civil law systems are those of France and Germany and, to some extent, Italy, which has recently incorporated aspects of the adversarial system. Common law systems account for another 20 percent of the world’s legal sys- tems. These are commonly referred to as “adversarial systems” because the fi nd- ing of guilt is not conducted by the magistrate who decides and investigates the case as in civil law rather, a prosecutor (or sometimes an investigating police offi cer) investigates the case and prepares the case for a trial by judge and jury