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	ComorosReviewed	OmanReviewed	SamoaReviewed
Legal family	Mixed French civil law and Islamic law	Mixed (civil law and Islamic law)	Common law with customary law
System of government	Federal presidential republic	Unitary absolute monarchy	Unitary parliamentary republic
Constitution	Constitution of the Union of the Comoros	Basic Law of the State	Constitution of the Independent State of Samoa
In force since	2001	1996	1962
Capital	Moroni	Muscat	Apia
Official languages	Comorian, Arabic, French	Arabic	Samoan, English
Currency	Comorian franc (KMF)	Omani rial (OMR)	Samoan tālā (WST)
Population	850,000	4,600,000	220,000
Division of powers	Federal. Grande Comore, Anjouan and Mohéli each have a governor and their own assembly with substantial autonomy over local administration, while the Union handles defence, currency, foreign affairs and nationality.	Unitary. Eleven governorates headed by appointed governors, with municipal councils holding advisory functions over local services. No legislative competence exists below the national level.	Unitary. Parliament legislates for the whole country. Below it, about 250 villages govern themselves through the village fono (council of matai) under the Village Fono Act 1990, which gives customary village authority statutory recognition — a genuine layer of local government rather than a delegation of central power.
How law is made	Bills originate with the government or members of the Assembly of the Union, are examined in committee and passed by the Assembly, then promulgated by the President. Matters within island competence are legislated by the island assemblies, and disputes over the boundary between Union and island competence are a standing feature of Comorian constitutional practice.	Draft legislation is prepared by ministries and the Council of Ministers, may be referred to the Council of Oman for review, and takes effect on the Sultan's signature and publication in the Official Gazette. The Majlis al-Shura may propose legislation and question ministers, and its role was modestly strengthened after 2011, but it cannot enact or block a royal decree.	Bills are read three times in the Legislative Assembly, usually with parliamentary committee scrutiny, and are then assented to by the O le Ao o le Malo. Ordinary bills need a simple majority. Constitutional amendments require a two-thirds majority of all members at the third reading, and any amendment affecting customary land or matai titles is politically entrenched by the strength of the fa'a Samoa consensus even where the two-thirds threshold is met.
Legal profession	A small bar of avocats admitted after French-model legal training, supplemented by qadis who require religious-law qualification for the personal-status jurisdiction; many practitioners train in France or Madagascar.	Advocacy is regulated by the Ministry of Justice and Legal Affairs; Omani nationality is required for rights of audience, and foreign lawyers practise as consultants within licensed firms. Pleadings are in Arabic. Judges are appointed by royal decree on the recommendation of the Supreme Judicial Council. Notarisation is required for real property dispositions, and land registration is administered by the Ministry of Housing and Urban Planning.	A fused profession under the Lawyers and Legal Practice Act 2014: lawyers are admitted by the Supreme Court and must hold a practising certificate from the Samoa Law Society. Most qualify at the University of the South Pacific or in New Zealand. Practice before the Land and Titles Court is different in character from ordinary litigation, because the issues are matai genealogy and customary entitlement rather than statutory or common-law rights.

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.