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.
Select up to six documented jurisdictions
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| Attribute | ChinaReviewed | MaltaReviewed | KuwaitReviewed |
|---|---|---|---|
| Legal family | Socialist civil law | Mixed (civil and common law) | Mixed (civil law and Islamic law) |
| System of government | Socialist one-party republic | Unitary parliamentary republic | Unitary constitutional monarchy |
| Constitution | Constitution of the People's Republic of China | Constitution of Malta | Constitution of the State of Kuwait |
| In force since | 1982 | 1964 | 1962 |
| Capital | Beijing | Valletta | Kuwait City |
| Official languages | Standard Chinese (Putonghua) | Maltese, English | Arabic |
| Currency | Renminbi (CNY) | Euro (EUR) | Kuwaiti dinar (KWD) |
| Population | 1,410,000,000 | 540,000 | 4,300,000 |
| Division of powers | 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. | A parliamentary republic with a ceremonial President, a Cabinet led by the Prime Minister answerable to the House of Representatives and an independent judiciary. | Unitary. Six governorates administered by appointed governors, with no legislative competence. |
| How law is made | 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. | Bills are passed by the House of Representatives and assented to by the President before publication in the Government Gazette. | Under the constitution as designed, bills passed by the National Assembly required Emiri sanction, and the Emir could return a bill for reconsideration which the Assembly could override by a two-thirds majority. With the Assembly dissolved and the relevant articles suspended since May 2024, legislation is made by Emiri decree on the proposal of the Council of Ministers and published in the Official Gazette (Kuwait Al-Youm). |
| Legal profession | 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. | Advocates are admitted to the bar after a law degree and warrant; legal procurators and notaries handle procedural filing and authentication of deeds. | Advocacy is reserved to Kuwaiti nationals enrolled with the Ministry of Justice and the Kuwait Bar Association, with foreign lawyers acting as consultants and unable to appear; pleadings are in Arabic. Judges are appointed by the Supreme Judicial Council, and a significant proportion of the bench has historically been seconded from other Arab states. Notarial authentication at the Ministry of Justice is required for powers of attorney, property transfers and company formation documents. |
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.