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 | LibyaIndexed | MadagascarReviewed | NepalReviewed |
|---|---|---|---|
| Legal family | Civil law with Islamic law as a source | French civil law with customary law | Mixed common law and Hindu customary tradition |
| System of government | Provisional government with contested authority | Semi-presidential republic | Federal parliamentary republic |
| Constitution | Constitutional Declaration (interim) | Constitution of the Fourth Republic | Constitution of Nepal |
| In force since | 2011 | 2010 | 2015 |
| Capital | Tripoli | Antananarivo | Kathmandu |
| Official languages | Arabic | Malagasy, French | Nepali |
| Currency | Libyan dinar (LYD) | Malagasy ariary (MGA) | Nepalese rupee (NPR) |
| Population | 6,900,000 | 30,300,000 | 30,500,000 |
| 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 a decentralised structure of 23 regions and communes. Successive constitutions have promised fuller decentralisation, including provincial autonomy, which has not been implemented. | Federal with three tiers: one federal government, seven provinces and 753 local units, each with its own elected assembly and schedule of exclusive powers. This is a genuine constitutional division rather than delegation — local units have taxing and legislative competence — and much post-2015 litigation concerns the boundaries between tiers and the slow transfer of staff and revenue. |
| 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. | Bills originate with the government or members of either chamber, are examined in committee, and must pass both the National Assembly and the Senate; the Assembly prevails on disagreement. The Haute Cour Constitutionnelle may review a law before promulgation, and organic laws must be referred to it as a matter of course. | Bills pass both federal houses, except money bills which originate in the House of Representatives; the President must assent. Constitutional amendment requires a two-thirds majority in both houses and, where a provision affects provincial boundaries or powers, the consent of a majority of provincial assemblies. Provinces and local units legislate within their own schedules. |
| 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. | Avocats admitted to the Ordre des avocats de Madagascar after a law degree and professional training, alongside notaires for authenticated instruments and huissiers for service and enforcement — the standard French division of functions. | Advocates are licensed by the Nepal Bar Council after a law degree and the Council's examination, with tiers of pleader, advocate and senior advocate. A single licence permits appearance at all levels, and the Nepal Bar Association is the professional body. Legal aid is provided under the Legal Aid Act 1997 through district committees, and the Constitution guarantees free legal aid to indigent parties. |
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.