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Comparison

Read two legal systems against each other

Because every portal follows the same fifteen-section outline, the comparison is genuinely like-for-like rather than a collage of whatever each government happens to publish.

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Comparison of selected legal systems
AttributeBahrainReviewedNamibiaReviewedIndonesiaReviewed
Legal familyMixed (civil law and Islamic law)Mixed Roman-Dutch and English common lawMixed civil, customary and Islamic law
System of governmentUnitary constitutional monarchySemi-presidential republicPresidential republic
ConstitutionConstitution of the Kingdom of BahrainConstitution of the Republic of NamibiaConstitution of the Republic of Indonesia 1945
In force since200219901945
CapitalManamaWindhoekJakarta
Official languagesArabicEnglishIndonesian
CurrencyBahraini dinar (BHD)Namibian dollar (NAD)Indonesian rupiah (IDR)
Population1,500,0002,600,000281,600,000
Division of powersUnitary. Four governorates administered centrally; elected municipal councils were abolished as a tier in 2014 and their functions transferred to the governorates.Unitary with 14 administrative regions and elected regional councils, which also constitute the National Council, the upper chamber. Traditional authorities exercise recognised functions over communal land and customary law.Unitary but heavily decentralised since the 1999 regional autonomy laws, which devolved most service delivery to some 500 regencies and cities rather than to the 38 provinces. Aceh, Papua and its successor provinces, Yogyakarta and Jakarta hold special autonomy statuses with distinct arrangements — Aceh includes Sharia jurisdiction and its own political parties; Yogyakarta's governor is hereditary.
How law is madeBills require passage by both chambers. Where they disagree, a joint sitting decides by majority with the Speaker of the appointed Consultative Council presiding and casting the deciding vote, which structurally favours the appointed chamber. The King ratifies and promulgates; a returned bill requires a two-thirds majority of the joint Assembly to be re-enacted. Decree-laws may be issued between sessions and must be submitted to the Assembly afterwards.Bills pass the National Assembly through three readings, then go to the National Council for review. The Council may confirm, propose amendments, or object; the Assembly can override an objection by a two-thirds majority. The President then assents, and constitutional amendments require two-thirds of both chambers and may never diminish the rights chapter.Bills may originate with the DPR, the President or the DPD on regional matters, and require the agreement of both the DPR and the President — a genuine joint enactment rather than assent. Once approved the President promulgates; if he does not, the bill becomes law after 30 days. The Constitutional Court may then annul it. The 2020 Job Creation Law was found conditionally unconstitutional for defective process, which forced the enactment of a new law on legislative drafting.
Legal professionAdvocates are licensed by the Ministry of Justice; Bahraini nationality is required for rights of audience before the higher courts, and foreign firms practise in association with local counsel. Bahrain is unusual in the region for the number of foreign firms permitted to advise, reflecting its role as a financial centre. Judges are appointed by royal order on the recommendation of the Supreme Judicial Council, and notarial authentication is required for property transfers and powers of attorney.A fused profession under the Legal Practitioners Act: a single class of legal practitioner is admitted after a law degree and the Justice Training Centre's postgraduate course, and the Law Society of Namibia regulates practice.Advocates are admitted under the Advocate Law 2003 after a law degree, a professional course, the bar examination and two years' apprenticeship, then sworn in by a High Court. PERADI is the principal bar association, though the profession has been divided by competing organisations, and the Constitutional Court has held that multiple bars may coexist while a single body administers admission. Notaries are a separate regulated profession with exclusive competence over deeds of incorporation and land transfers.

A comparison table flattens nuance by design. Where a difference matters to a decision you are making, open both portals and read the section in full — the constitutional detail behind a one-line summary is often the part that governs the outcome.