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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| Attribute | LibyaIndexed | IranReviewed | BeninReviewed |
|---|---|---|---|
| Legal family | Civil law with Islamic law as a source | Islamic law with civil law codification | Civil law (French tradition) |
| System of government | Provisional government with contested authority | Islamic republic | Unitary presidential republic |
| Constitution | Constitutional Declaration (interim) | Constitution of the Islamic Republic of Iran | Constitution of the Republic of Benin |
| In force since | 2011 | 1979 | 1990 |
| Capital | Tripoli | Tehran | Porto-Novo |
| Official languages | Arabic | Persian | French, Fon, Yoruba |
| Currency | Libyan dinar (LYD) | Rial (IRR) | West African CFA franc (XOF) |
| Population | 6,900,000 | 89,000,000 | 13,700,000 |
| Division of powers | Nominally unitary with governorates and municipalities. In practice authority is divided between competing administrations and local armed actors, and municipal councils have in many places become the most functional layer of government. | Unitary, 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 without a Prime Minister for most of its history, a unicameral National Assembly, and a Constitutional Court with broad access rules. |
| How law is made | There is no single functioning legislative process. The House of Representatives passes laws that the High Council of State contests, and the rival administrations issue decrees within their areas of control. Whether a given instrument is law therefore depends on which authority is recognised, which is exactly why this profile is marked as requiring research rather than described as settled. | A 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 are examined in committee and voted in plenary by the National Assembly. The President promulgates; the Constitutional Court may be seised before or after promulgation, including by individuals. |
| Legal profession | Advocates are admitted through the Libyan Bar Association, and the profession has continued to function, including in human-rights litigation, despite serious risks to practitioners. Judicial appointments run through the Supreme Judicial Council. Reliable current information on admission requirements and numbers is limited, which is reflected in the verification status of this entry. | Two 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. | Avocats admitted through the Barreau du Bรฉnin; notaires and huissiers are separate ministerial officers. |
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.