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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
AttributeBruneiReviewedGrenadaReviewedChinaReviewed
Legal familyMixed common law and Islamic lawCommon lawSocialist civil law
System of governmentAbsolute monarchyConstitutional monarchySocialist one-party republic
ConstitutionConstitution of Brunei DarussalamThe Grenada ConstitutionConstitution of the People's Republic of China
In force since195919731982
CapitalBandar Seri BegawanSaint George'sBeijing
Official languagesMalay, EnglishEnglishStandard Chinese (Putonghua)
CurrencyBrunei dollar (BND)East Caribbean dollar (XCD)Renminbi (CNY)
Population450,000126,0001,410,000,000
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, with a highly asymmetric structure: 23 provinces, five autonomous regions, four directly administered municipalities and two special administrative regions. Hong Kong and Macao operate under 'one country, two systems' with their own Basic Laws, their own courts of final appeal, and legal systems that remain common-law and Portuguese-derived civil-law respectively. Provincial people's congresses may enact local regulations that must not contravene national law.
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.The NPC meets in plenary once a year, so the Standing Committee enacts most legislation. A bill is normally read three times under the Legislation Law, with drafts published for public comment — the Civil Code drafts drew over a million submissions. The NPCSC also has power to interpret laws, which it exercises as a substantive lawmaking tool. There is no presidential veto: the President promulgates what the NPC or its Standing Committee has passed.
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.Lawyers are licensed under the Lawyers Law after passing the National Unified Legal Profession Qualification Examination, which since 2018 has also been the common entry route for judges, prosecutors and notaries. Firms are licensed and subject to annual inspection by provincial justice departments, and membership of the All China Lawyers Association is mandatory. A 2012 amendment to the Lawyers Law requires an oath that includes loyalty to the leadership of the Communist Party, and the annual licence renewal is the principal point of leverage over practitioners in politically sensitive work.

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.