and Zoroastrian legal systems, highlighting the function of the judiciary, the social standing of the judges in their respective societies and their relations vis-à-vis jurisprudence. Since these legal systems are called ‘religious’ in legal literature, giving the impression that it is religion which is their most important feature, it is necessary to compare postulations of legal theory to legal practice in order to show the relationship between theory and practice. We can find in the works of some authors of comparative law (e.g. Sola Ca?izares, Adolf Schnitzer and René David)1 the concept of religious legal system, although the definition of religion itself is rather complex and subject to various interpretations. To refer to just one obvious example, there is hardly any similarity between the Chinese concepts of religion (universalism, Taoism, yin-yang school etc.) and those of the revealed religions (the religions of the book). Moreover, there are so many schools and interpretations within Hinduism that one can hardly speak about any uniform ‘ism’. If religious foundations taken for granted in legal literature are so diverse and complex, how much more the legal systems built on them would be. Thus, it is problematic to put such different legal systems under the aegis of one rather enigmatic category. With some exceptions, however, these considerations are not present in comparative legal literature since in the majority of cases it is the erudition and interest of the author and limited space which determine what comes under the aegis of religious legal systems. Hindu law and Islamic law are always discussed in comparative legal works because of their importance, influence and the great number of their followers. By contrast, Jewish and Canon law are discussed very briefly, if not omitted altogether; meanwhile Zoroastrian law is considered as not worth mentioning. Consequently, not only the definition of the term ‘religious legal system’ is missing, but also the exact enumeration of the individual legal systems covered by this category.