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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
AttributeIranReviewedUgandaReviewedKuwaitReviewed
Legal familyIslamic law with civil law codificationMixed (common law and customary law)Mixed (civil law and Islamic law)
System of governmentIslamic republicUnitary presidential republicUnitary constitutional monarchy
ConstitutionConstitution of the Islamic Republic of IranConstitution of the Republic of UgandaConstitution of the State of Kuwait
In force since197919951962
CapitalTehranKampalaKuwait City
Official languagesPersianEnglish, Swahili, LugandaArabic
CurrencyRial (IRR)Ugandan Shilling (UGX)Kuwaiti dinar (KWD)
Population89,000,00048,600,0004,300,000
Division of powersUnitary, 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.Presidential system with a Prime Minister, a unicameral Parliament, and a judiciary in which the Supreme Court, Court of Appeal (sitting also as the Constitutional Court) and High Court form the superior courts.Unitary. Six governorates administered by appointed governors, with no legislative competence.
How law is madeA 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 receive three readings with committee scrutiny; certificates of financial implication are required for money bills. The President assents, returns the bill twice with recommendations, or it becomes law if passed a third time by two-thirds.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 professionTwo 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.Fused; an LLB, the Law Development Centre post-graduate diploma and enrolment admit an advocate. The Uganda Law Society is the professional body.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.