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 | CyprusReviewed | LesothoReviewed |
|---|---|---|---|
| Legal family | Islamic law with civil law codification | Mixed common law and civil law | Mixed Roman-Dutch and English common law |
| System of government | Islamic republic | Unitary presidential republic | Parliamentary constitutional monarchy |
| Constitution | Constitution of the Islamic Republic of Iran | Constitution of the Republic of Cyprus | Constitution of Lesotho |
| In force since | 1979 | 1960 | 1993 |
| Capital | Tehran | Nicosia | Maseru |
| Official languages | Persian | Greek, Turkish | Sesotho, English |
| Currency | Rial (IRR) | Euro (EUR) | Lesotho loti (LSL) |
| Population | 89,000,000 | 1,260,000 | 2,300,000 |
| 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, with districts administered centrally and elected municipalities. In practice the government exercises effective control over roughly the southern two-thirds of the island; the north has been separately administered since 1974 under an entity recognised only by Turkey, and the application of the EU acquis is suspended there under Protocol 10 to the Accession Treaty. The atlas describes the law of the Republic and notes where it is not effectively applied. | 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. |
| 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 are introduced by ministers or members and passed by the House of Representatives. The President may return a law for reconsideration or refer it to the Supreme Court for a constitutionality ruling before promulgation; if the Court finds no conflict, promulgation follows. Laws enter into force on publication in the Official Gazette unless otherwise provided, and EU obligations are frequently implemented by harmonising statute and regulation. | 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. |
| 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. | A fused profession of advocates admitted under the Advocates Law after a law degree, the Legal Council examinations and a twelve-month pupillage, with compulsory membership of the Cyprus Bar Association. Many practitioners qualify in the United Kingdom or Greece, and English-language practice is standard in commercial work. Advocates hold a monopoly on court representation and on certifying company documents, and the profession is unusually large per head of population because of the international corporate and trusts business. | 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. |
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.