Comparison of Legal Systems in ASEAN Countires From a Regional Legal Perspective

Abstract

This article examines the comparative legal systems of the member states of the Association of Southeast Asian Nations (ASEAN), emphasizing the diversity of legal traditions, institutional structures, and their implications for national and regional legal development. ASEAN consists of countries with heterogeneous historical, political, and cultural backgrounds that significantly influence the formation of their respective legal systems. Using a normative and conceptual comparative legal approach, this study analyzes civil law systems, common law systems, mixed legal systems, and legal systems influenced by religious and socialist law traditions. The discussion focuses on constitutional law, state administrative law, criminal law, civil law, and human rights protection within the ASEAN region. The findings show that despite fundamental differences among ASEAN legal systems, there are shared legal values that can serve as a foundation for regional legal harmonization. Comparative legal studies in ASEAN are not only academically relevant but also play a strategic role in supporting regional integration, cross-border cooperation, and the development of a more coherent ASEAN legal framework.