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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| Attribute | IranReviewed | BahrainReviewed |
|---|---|---|
| Legal family | Islamic law with civil law codification | Mixed (civil law and Islamic law) |
| System of government | Islamic republic | Unitary constitutional monarchy |
| Constitution | Constitution of the Islamic Republic of Iran | Constitution of the Kingdom of Bahrain |
| In force since | 1979 | 2002 |
| Capital | Tehran | Manama |
| Official languages | Persian | Arabic |
| Currency | Rial (IRR) | Bahraini dinar (BHD) |
| Population | 89,000,000 | 1,500,000 |
| Division of powers | Unitary, with 31 provinces headed by governors-general appointed by the Interior Ministry, alongside elected city and village councils created by the Constitution and operating since 1999 with limited competences. | Unitary. Four governorates administered centrally; elected municipal councils were abolished as a tier in 2014 and their functions transferred to the governorates. |
| How law is made | A bill is introduced by the Government or by at least fifteen deputies, passes the Majlis, and goes to the Guardian Council, which has ten days, extendable, to find it consistent with Islam and the Constitution. If the Council objects, the bill returns for amendment; persistent disagreement goes to the Expediency Discernment Council, whose decision is final. Only then does the President sign and publish. | Bills require passage by both chambers. Where they disagree, a joint sitting decides by majority with the Speaker of the appointed Consultative Council presiding and casting the deciding vote, which structurally favours the appointed chamber. The King ratifies and promulgates; a returned bill requires a two-thirds majority of the joint Assembly to be re-enacted. Decree-laws may be issued between sessions and must be submitted to the Assembly afterwards. |
| Legal profession | Two parallel routes to practice, which is unusual and consequential: attorneys licensed by the Iranian Bar Association (Kanoon-e Vokala), a self-governing body dating to 1953, and attorneys licensed under Article 187 of the Third Development Plan directly by the judiciary. The two groups have contested each other's standing for two decades. Notaries operate licensed offices under the registration organisation, and their authentication is required for property transfers, marriage contracts and powers of attorney. | Advocates are licensed by the Ministry of Justice; Bahraini nationality is required for rights of audience before the higher courts, and foreign firms practise in association with local counsel. Bahrain is unusual in the region for the number of foreign firms permitted to advise, reflecting its role as a financial centre. Judges are appointed by royal order on the recommendation of the Supreme Judicial Council, and notarial authentication is required for property transfers and powers of attorney. |
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.