Comparison

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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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Comparison of selected legal systems
Attribute	LibyaIndexed	TongaReviewed	BruneiReviewed
Legal family	Civil law with Islamic law as a source	Common law with customary law	Mixed common law and Islamic law
System of government	Provisional government with contested authority	Constitutional monarchy	Absolute monarchy
Constitution	Constitutional Declaration (interim)	Act of Constitution of Tonga	Constitution of Brunei Darussalam
In force since	2011	1875	1959
Capital	Tripoli	Nuku'alofa	Bandar Seri Begawan
Official languages	Arabic	Tongan, English	Malay, English
Currency	Libyan dinar (LYD)	Tongan paʻanga (TOP)	Brunei dollar (BND)
Population	6,900,000	105,000	450,000
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. The Legislative Assembly legislates for the whole kingdom, and the island divisions of Tongatapu, Vava'u, Ha'apai, 'Eua and the Niuas are administrative districts headed by governors. Below that, town and district officers are elected under the Fakafekau'aki and District and Town Officers Act.	Unitary, with four districts administered by district officers reporting to the Ministry of Home Affairs. No federal or devolved tier; village and mukim headmen have recognised consultative functions.
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 pass three readings in the Legislative Assembly and require the King's assent, which is a real rather than purely formal step. Ordinary bills need a simple majority. Amendments to the Constitution require a majority in the Assembly at three separate readings and the consent of the King and Privy Council, and clause 79 forbids any amendment affecting the law of liberty, the succession to the throne or the titles and hereditary estates of the nobles.	In form, bills are introduced in the Legislative Council and assented to by the Sultan. In practice the significant instruments are Orders made by the Sultan under the emergency proclamation, which take effect on publication in the Government Gazette without Council passage. The Syariah Penal Code Order 2013 was enacted this way.
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.	Law practitioners are admitted by the Chief Justice and licensed under the Law Practitioners Act, with the Tonga Law Society as the professional body. Most qualify overseas or at the University of the South Pacific. A practitioner working on land must know the Land Act's allotment system rather than general property law, because the constitutional bar on selling land means conveyancing in the ordinary sense does not exist.	Advocates and solicitors are admitted by the High Court under the Legal Profession Act, generally after qualifying in England, Malaysia, Singapore or Australia and completing local requirements. The profession is small — a few hundred practitioners — and foreign counsel may be admitted ad hoc for particular cases. Syariah practice is a separate track: Syariah lawyers are certified under the Syariah Courts Act and appear only in the Syariah hierarchy, so a matter that crosses both systems needs two sets of representation.

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.