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
Attribute	BahrainReviewed	NamibiaReviewed	MalaysiaReviewed
Legal family	Mixed (civil law and Islamic law)	Mixed Roman-Dutch and English common law	Mixed common law and Islamic law
System of government	Unitary constitutional monarchy	Semi-presidential republic	Federal constitutional monarchy
Constitution	Constitution of the Kingdom of Bahrain	Constitution of the Republic of Namibia	Federal Constitution of Malaysia
In force since	2002	1990	1957
Capital	Manama	Windhoek	Kuala Lumpur
Official languages	Arabic	English	Malay, English
Currency	Bahraini dinar (BHD)	Namibian dollar (NAD)	Malaysian ringgit (MYR)
Population	1,500,000	2,600,000	34,100,000
Division of powers	Unitary. 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.	Federal, with 13 states and three federal territories. The Ninth Schedule sets out Federal, State and Concurrent Lists: land, Islamic law, Malay custom and local government are state matters, while trade, finance, defence and civil and criminal law are federal. Sabah and Sarawak hold additional competences — immigration, native customary land, and their own High Court — reflecting the terms on which they joined.
How law is made	Bills 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 pass both houses; the Dewan Negara can delay but not block, and money bills originate in the Dewan Rakyat. Royal assent is required and, since a 1994 amendment, is deemed given after 30 days if withheld. Amendments affecting the rulers, the special position of the Malays, citizenship or the position of Sabah and Sarawak require additional consents beyond the two-thirds majority.
Legal profession	Advocates 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.	A fused profession of advocates and solicitors, but regulated separately by territory: the Malaysian Bar under the Legal Profession Act 1976 for Peninsular Malaysia, the Sabah Law Society, and the Advocates Association of Sarawak. Admission requires a recognised law degree or the Certificate in Legal Practice, pupillage of nine months, and admission by the High Court. Syariah practitioners are separately admitted by state Syariah authorities and require Syariah law qualifications.

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.