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 | KuwaitReviewed | MaltaReviewed |
|---|---|---|---|
| Legal family | Civil law with Islamic law influence | Mixed (civil law and Islamic law) | Mixed (civil and common law) |
| System of government | Federal parliamentary republic | Unitary constitutional monarchy | Unitary parliamentary republic |
| Constitution | Constitution of the Republic of Iraq | Constitution of the State of Kuwait | Constitution of Malta |
| In force since | 2005 | 1962 | 1964 |
| Capital | Baghdad | Kuwait City | Valletta |
| Official languages | Arabic, Kurdish | Arabic | Maltese, English |
| Currency | Iraqi dinar (IQD) | Kuwaiti dinar (KWD) | Euro (EUR) |
| Population | 45,500,000 | 4,300,000 | 540,000 |
| 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. Six governorates administered by appointed governors, with no legislative competence. | A parliamentary republic with a ceremonial President, a Cabinet led by the Prime Minister answerable to the House of Representatives and an independent judiciary. |
| 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. | 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). | Bills are passed by the House of Representatives and assented to by the President before publication in the Government Gazette. |
| 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. | 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. | Advocates are admitted to the bar after a law degree and warrant; legal procurators and notaries handle procedural filing and authentication of deeds. |
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.