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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
AttributeLesothoReviewedCubaReviewedKuwaitReviewed
Legal familyMixed Roman-Dutch and English common lawSocialist civil lawMixed (civil law and Islamic law)
System of governmentParliamentary constitutional monarchyOne-party socialist republicUnitary constitutional monarchy
ConstitutionConstitution of LesothoConstituciรณn de la Repรบblica de CubaConstitution of the State of Kuwait
In force since199320191962
CapitalMaseruHavanaKuwait City
Official languagesSesotho, EnglishSpanishArabic
CurrencyLesotho loti (LSL)Cuban peso (CUP)Kuwaiti dinar (KWD)
Population2,300,00011,200,0004,300,000
Division of powersUnitary 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.Unitary, organised on the principle of a single system of state power. The 2019 Constitution and the 2019 territorial reform recognise 15 provinces and the special municipality of Isla de la Juventud, with provincial governors appointed on the President's nomination.Unitary. Six governorates administered by appointed governors, with no legislative competence.
How law is madeBills 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.Legislative initiative lies with deputies, the Council of State, the Council of Ministers, the courts, the Prosecutor General, mass organisations and 10,000 citizens by popular initiative. The Assembly meets in short ordinary sessions, so much law is made by decree-law of the Council of State and subsequently ratified. Constitutional amendment requires two-thirds of the Assembly, and a referendum for provisions on the political system or rights.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 professionA split profession in form โ€” advocates and attorneys are separately admitted under the Legal Practitioners Act โ€” though in practice many practitioners hold both admissions; the Law Society of Lesotho regulates the attorneys' branch.Practising litigators generally work through the Organizaciรณn Nacional de Bufetes Colectivos, a self-financing national body of collective law offices; independent private practice is not a recognised route. Membership of the Uniรณn Nacional de Juristas de Cuba is the professional association. Notarial functions are performed by state notaries.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 โ€” the constitutional detail behind a one-line summary is often the part that governs the outcome.