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	FijiReviewed	LesothoReviewed	MadagascarReviewed
Legal family	Common law with customary law	Mixed Roman-Dutch and English common law	French civil law with customary law
System of government	Unitary parliamentary republic	Parliamentary constitutional monarchy	Semi-presidential republic
Constitution	Constitution of the Republic of Fiji	Constitution of Lesotho	Constitution of the Fourth Republic
In force since	2013	1993	2010
Capital	Suva	Maseru	Antananarivo
Official languages	English, Fijian, Fiji Hindi	Sesotho, English	Malagasy, French
Currency	Fijian dollar (FJD)	Lesotho loti (LSL)	Malagasy ariary (MGA)
Population	930,000	2,300,000	30,300,000
Division of powers	Unitary and deliberately centralised. Section 1 declares Fiji a sovereign state whose Parliament legislates for the whole country; there are no provinces with legislative power. The 14 provincial councils and the iTaukei Affairs Board administer indigenous affairs under the iTaukei Affairs Act. Rotuma has a distinct status under the Rotuma Act.	Unitary with ten districts, and a recognised hierarchy of chiefs exercising customary functions over land allocation and local dispute resolution. The Senate includes the twenty-two principal chiefs ex officio.	Unitary with a decentralised structure of 23 regions and communes. Successive constitutions have promised fuller decentralisation, including provincial autonomy, which has not been implemented.
How law is made	Bills are introduced in the unicameral Parliament, referred to a standing committee, and pass through second reading, committee and third reading before assent by the President. There is no upper house. A constitutional amendment requires the support of three-quarters of all members of Parliament and then approval by three-quarters of registered voters at a referendum, a threshold that has never been met.	Bills pass three readings in the National Assembly, go to the Senate for review, and receive royal assent. The Senate can delay but not indefinitely block ordinary bills. Amendments to entrenched constitutional provisions require a two-thirds majority and, for the most protected clauses, a referendum.	Bills originate with the government or members of either chamber, are examined in committee, and must pass both the National Assembly and the Senate; the Assembly prevails on disagreement. The Haute Cour Constitutionnelle may review a law before promulgation, and organic laws must be referred to it as a matter of course.
Legal profession	A fused profession under the Legal Practitioners Act 2009: practitioners are admitted by the Chief Justice as barristers and solicitors. Most qualify through the University of the South Pacific law degree followed by the Professional Diploma in Legal Practice. Admission and discipline are handled by the Chief Registrar and the Independent Legal Services Commission rather than by the Fiji Law Society, which is a voluntary professional body.	A split profession in form — advocates and attorneys are separately admitted under the Legal Practitioners Act — though in practice many practitioners hold both admissions; the Law Society of Lesotho regulates the attorneys' branch.	Avocats admitted to the Ordre des avocats de Madagascar after a law degree and professional training, alongside notaires for authenticated instruments and huissiers for service and enforcement — the standard French division of functions.

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.