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.
Select up to six documented jurisdictions
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| Attribute | IraqReviewed | EswatiniReviewed | NamibiaReviewed |
|---|---|---|---|
| Legal family | Civil law with Islamic law influence | Mixed Roman-Dutch, English common law and Swazi customary law | Mixed Roman-Dutch and English common law |
| System of government | Federal parliamentary republic | Absolute monarchy | Semi-presidential republic |
| Constitution | Constitution of the Republic of Iraq | Constitution of the Kingdom of Eswatini | Constitution of the Republic of Namibia |
| In force since | 2005 | 2005 | 1990 |
| Capital | Baghdad | Mbabane | Windhoek |
| Official languages | Arabic, Kurdish | siSwati, English | English |
| Currency | Iraqi dinar (IQD) | Swazi lilangeni (SZL) | Namibian dollar (NAD) |
| Population | 45,500,000 | 1,200,000 | 2,600,000 |
| Division of powers | Genuinely federal in form: 15 governorates not organised into a region, plus the Kurdistan Region, which has its own Parliament, government, judiciary and security forces. Governorates may petition to form new regions. Residual powers lie with the regions and governorates rather than the centre, and regional law prevails over federal law outside the exclusive federal competences — the reverse of the usual federal rule. | Unitary with four regions and 55 tinkhundla constituencies that combine electoral and administrative functions. Chiefs administer Swazi Nation Land under the King as trustee. | Unitary with 14 administrative regions and elected regional councils, which also constitute the National Council, the upper chamber. Traditional authorities exercise recognised functions over communal land and customary law. |
| How law is made | Bills are proposed by the President with the Council of Ministers, or by ten members or a committee of the Council of Representatives. They pass two readings and a vote, and the President ratifies within fifteen days, after which they are published and take effect. The Federation Council envisaged by the Constitution has never been created, so there is no second chamber in practice. | Bills pass the House of Assembly and Senate and require royal assent, which the King may withhold. The King may also legislate by decree in defined circumstances, and bills touching Swazi law and custom are referred to traditional structures. Constitutional amendment requires a two-thirds majority of both chambers sitting jointly, and for entrenched provisions a referendum. | Bills pass the National Assembly through three readings, then go to the National Council for review. The Council may confirm, propose amendments, or object; the Assembly can override an objection by a two-thirds majority. The President then assents, and constitutional amendments require two-thirds of both chambers and may never diminish the rights chapter. |
| Legal profession | Lawyers are admitted by the Iraqi Bar Association under the Advocacy Law, with grades of practice determining which courts a member may appear in — a seniority ladder rather than a single right of audience. The Bar is self-governing and its licence is required for court work. The Kurdistan Region has its own bar association, and the two are administratively distinct, so practitioners generally hold the licence appropriate to where they appear. | A fused profession of attorneys admitted by the High Court after a law degree and articles, regulated by the Law Society of Eswatini; advocates may be admitted separately for higher-court work. | A fused profession under the Legal Practitioners Act: a single class of legal practitioner is admitted after a law degree and the Justice Training Centre's postgraduate course, and the Law Society of Namibia regulates practice. |
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.