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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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Comparison of selected legal systems
AttributeMadagascarReviewedChileReviewedMoroccoReviewed
Legal familyFrench civil law with customary lawCivil lawCivil law with Islamic law in personal status
System of governmentSemi-presidential republicUnitary presidential republicConstitutional monarchy
ConstitutionConstitution of the Fourth RepublicPolitical Constitution of the Republic of ChileConstitution of the Kingdom of Morocco
In force since201019802011
CapitalAntananarivoSantiagoRabat
Official languagesMalagasy, FrenchSpanishArabic, Tamazight
CurrencyMalagasy ariary (MGA)Chilean peso (CLP)Moroccan dirham (MAD)
Population30,300,00019,600,00037,500,000
Division of powersUnitary with a decentralised structure of 23 regions and communes. Successive constitutions have promised fuller decentralisation, including provincial autonomy, which has not been implemented.Unitary. Sixteen regions administer but do not legislate. Regional governors have been directly elected since 2021, which shifted real power away from the centrally appointed delegates, but legislative competence remains exclusively national.Unitary but substantially regionalised since 2015, with twelve regions holding directly elected councils and their own budgets under the advanced regionalisation programme. Regions have executive competences in development planning and transport; they do not legislate.
How law is madeBills 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 originate with the President or in either chamber, though tax, budget and social-security bills are the President's exclusive initiative โ€” an unusually strong executive agenda power. Both chambers must approve; a mixed committee resolves conflict. The President may veto, overridden by two-thirds. Constitutional amendment needs four-sevenths of sitting members, with two-thirds for certain entrenched chapters.Bills may be introduced by the head of government or by members of either chamber. They pass through committee and plenary in both houses, with the House of Representatives having the final word where the chambers disagree. Organic laws must be referred to the Constitutional Court before promulgation. The King promulgates statutes by dahir within thirty days, and may ask parliament to reconsider a bill or submit it to referendum.
Legal professionAvocats 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 โ€” the standard French division of functions.A five-year degree, a supervised practice period, and admission by the Supreme Court itself, which is unusual โ€” the Court, not a bar, confers the title of abogado. Membership of the Colegio de Abogados has been voluntary since 1981, so the Court retains disciplinary jurisdiction over misconduct.Avocats are admitted to one of the regional bars and organised nationally through the Association des Barreaux du Maroc; practice before the Court of Cassation requires additional seniority. Notaries and adouls coexist โ€” the notaire handles conveyancing and company documents in the French tradition, while the adoul draws up marriage and inheritance instruments under Islamic law. Judges are career appointments trained at the Institut Supรฉrieur de la Magistrature.

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.