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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
AttributeBruneiReviewedNew ZealandReviewed
Legal familyMixed common law and Islamic lawCommon law
System of governmentAbsolute monarchyConstitutional monarchy
ConstitutionConstitution of Brunei DarussalamUncodified โ€” principally the Constitution Act 1986
In force since19591986
CapitalBandar Seri BegawanWellington
Official languagesMalay, EnglishEnglish, Mฤori, New Zealand Sign Language
CurrencyBrunei dollar (BND)New Zealand dollar (NZD)
Population450,0005,200,000
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. Parliament legislates for the whole country and there are no states or provinces. Regional and territorial authorities exist only under the Local Government Act 2002 and exercise delegated statutory powers. Tokelau is a non-self-governing territory, while the Cook Islands and Niue are self-governing in free association with New Zealand and have their own legal systems.
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.A bill has a first reading, select committee scrutiny (usually with public submissions), second reading, committee of the whole House, and third reading, followed by Royal assent. There is no upper house, so the select committee stage carries the weight that a second chamber would elsewhere. The Attorney-General must report to the House under section 7 of the Bill of Rights Act on any bill that appears inconsistent with protected rights, but the House may pass it anyway. Reserved provisions of the Electoral Act 1993 require either 75% of all members or a majority at referendum.
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 โ€” a few hundred practitioners โ€” 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 under the Lawyers and Conveyancers Act 2006: a lawyer is admitted as a barrister and solicitor of the High Court, and may then practise as a barrister sole or in a firm. Admission requires an approved law degree, the Professional Legal Studies Course and a certificate of character. The New Zealand Law Society | Te Kฤhui Ture o Aotearoa regulates the profession, and King's Counsel are appointed from senior practitioners.

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 โ€” the constitutional detail behind a one-line summary is often the part that governs the outcome.