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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
AttributeBruneiReviewedGrenadaReviewedBahrainReviewed
Legal familyMixed common law and Islamic lawCommon lawMixed (civil law and Islamic law)
System of governmentAbsolute monarchyConstitutional monarchyUnitary constitutional monarchy
ConstitutionConstitution of Brunei DarussalamThe Grenada ConstitutionConstitution of the Kingdom of Bahrain
In force since195919732002
CapitalBandar Seri BegawanSaint George'sManama
Official languagesMalay, EnglishEnglishArabic
CurrencyBrunei dollar (BND)East Caribbean dollar (XCD)Bahraini dinar (BHD)
Population450,000126,0001,500,000
Division of powersUnitary, with four districts administered by district officers reporting to the Ministry of Home Affairs. No federal or devolved tier; village and mukim headmen have recognised consultative functions.Unitary. The state comprises Grenada, Carriacou and Petite Martinique; Carriacou and Petite Martinique have a Ministry and local administration but no separate legislature.Unitary. Four governorates administered centrally; elected municipal councils were abolished as a tier in 2014 and their functions transferred to the governorates.
How law is madeIn form, bills are introduced in the Legislative Council and assented to by the Sultan. In practice the significant instruments are Orders made by the Sultan under the emergency proclamation, which take effect on publication in the Government Gazette without Council passage. The Syariah Penal Code Order 2013 was enacted this way.Bills pass three readings in both Houses and receive the Governor-General's assent. Constitutional amendments to entrenched provisions need a two-thirds majority in the House of Representatives and then approval by a referendum, a double lock that has defeated every reform package put to voters.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.
Legal professionAdvocates and solicitors are admitted by the High Court under the Legal Profession Act, generally after qualifying in England, Malaysia, Singapore or Australia and completing local requirements. The profession is small — a few hundred practitioners — and foreign counsel may be admitted ad hoc for particular cases. Syariah practice is a separate track: Syariah lawyers are certified under the Syariah Courts Act and appear only in the Syariah hierarchy, so a matter that crosses both systems needs two sets of representation.A fused profession of legal practitioners admitted by the High Court under the Legal Profession Act, after a law degree and the Legal Education Certificate. The Grenada Bar Association represents practitioners.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 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.