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Comparison of selected legal systems
AttributeLesothoReviewedSudanIndexedKuwaitReviewed
Legal familyMixed Roman-Dutch and English common lawMixed Islamic and common lawMixed (civil law and Islamic law)
System of governmentParliamentary constitutional monarchyMilitary government following the 2021 coup and 2023 warUnitary constitutional monarchy
ConstitutionConstitution of LesothoDraft Constitutional Charter for the Transitional PeriodConstitution of the State of Kuwait
In force since199320191962
CapitalMaseruKhartoumKuwait City
Official languagesSesotho, EnglishArabic, EnglishArabic
CurrencyLesotho loti (LSL)Sudanese pound (SDG)Kuwaiti dinar (KWD)
Population2,300,00048,100,0004,300,000
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.Formally federal, with states headed by governors. The Juba Peace Agreement of 2020 contemplated regional arrangements for Darfur and the Two Areas. Effective authority is currently divided between the belligerents and varies by locality.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.The Charter assigned legislation to a joint sitting of the Sovereignty Council and the cabinet pending the formation of a legislative council, which never fully happened. Since 2021 instruments have been issued by decree. There is no verifiable ordinary legislative process at present, which is why this profile is marked as requiring research.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 — 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.Advocates are admitted through the Sudanese Bar Association, and the profession — particularly the Sudanese Professionals Association and the emergency lawyers' groups — was central to the 2019 protest movement and to documenting subsequent abuses. Judges are career appointments through the Judicial Service Commission. Current admission practice and numbers cannot be reliably confirmed.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.