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Comparison of selected legal systems
AttributeLibyaIndexedOmanReviewedFijiReviewed
Legal familyCivil law with Islamic law as a sourceMixed (civil law and Islamic law)Common law with customary law
System of governmentProvisional government with contested authorityUnitary absolute monarchyUnitary parliamentary republic
ConstitutionConstitutional Declaration (interim)Basic Law of the StateConstitution of the Republic of Fiji
In force since201119962013
CapitalTripoliMuscatSuva
Official languagesArabicArabicEnglish, Fijian, Fiji Hindi
CurrencyLibyan dinar (LYD)Omani rial (OMR)Fijian dollar (FJD)
Population6,900,0004,600,000930,000
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. Eleven governorates headed by appointed governors, with municipal councils holding advisory functions over local services. No legislative competence exists below the national level.Unitary and deliberately centralised. Section 1 declares Fiji a sovereign state whose Parliament legislates for the whole country; there are no provinces with legislative power. The 14 provincial councils and the iTaukei Affairs Board administer indigenous affairs under the iTaukei Affairs Act. Rotuma has a distinct status under the Rotuma Act.
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.Draft legislation is prepared by ministries and the Council of Ministers, may be referred to the Council of Oman for review, and takes effect on the Sultan's signature and publication in the Official Gazette. The Majlis al-Shura may propose legislation and question ministers, and its role was modestly strengthened after 2011, but it cannot enact or block a royal decree.Bills are introduced in the unicameral Parliament, referred to a standing committee, and pass through second reading, committee and third reading before assent by the President. There is no upper house. A constitutional amendment requires the support of three-quarters of all members of Parliament and then approval by three-quarters of registered voters at a referendum, a threshold that has never been met.
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.Advocacy is regulated by the Ministry of Justice and Legal Affairs; Omani nationality is required for rights of audience, and foreign lawyers practise as consultants within licensed firms. Pleadings are in Arabic. Judges are appointed by royal decree on the recommendation of the Supreme Judicial Council. Notarisation is required for real property dispositions, and land registration is administered by the Ministry of Housing and Urban Planning.A fused profession under the Legal Practitioners Act 2009: practitioners are admitted by the Chief Justice as barristers and solicitors. Most qualify through the University of the South Pacific law degree followed by the Professional Diploma in Legal Practice. Admission and discipline are handled by the Chief Registrar and the Independent Legal Services Commission rather than by the Fiji Law Society, which is a voluntary professional body.

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.