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Comparison of selected legal systems
AttributeLibyaIndexedIranReviewedLesothoReviewed
Legal familyCivil law with Islamic law as a sourceIslamic law with civil law codificationMixed Roman-Dutch and English common law
System of governmentProvisional government with contested authorityIslamic republicParliamentary constitutional monarchy
ConstitutionConstitutional Declaration (interim)Constitution of the Islamic Republic of IranConstitution of Lesotho
In force since201119791993
CapitalTripoliTehranMaseru
Official languagesArabicPersianSesotho, English
CurrencyLibyan dinar (LYD)Rial (IRR)Lesotho loti (LSL)
Population6,900,00089,000,0002,300,000
Division of powersNominally 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.Unitary 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.
How law is madeThere 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 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.
Legal professionAdvocates 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.A 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.

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.