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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
AttributeMauritiusReviewedGrenadaReviewedFijiReviewed
Legal familyMixed French civil law and English common lawCommon lawCommon law with customary law
System of governmentParliamentary republicConstitutional monarchyUnitary parliamentary republic
ConstitutionConstitution of MauritiusThe Grenada ConstitutionConstitution of the Republic of Fiji
In force since196819732013
CapitalPort LouisSaint George'sSuva
Official languagesEnglish, French, Mauritian CreoleEnglishEnglish, Fijian, Fiji Hindi
CurrencyMauritian rupee (MUR)East Caribbean dollar (XCD)Fijian dollar (FJD)
Population1,260,000126,000930,000
Division of powersUnitary, with Rodrigues holding a statutory autonomous status and its own Regional Assembly, and Agalega and St Brandon administered as outer islands.Unitary. The state comprises Grenada, Carriacou and Petite Martinique; Carriacou and Petite Martinique have a Ministry and local administration but no separate legislature.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 madeBills pass three readings in the National Assembly with committee scrutiny and receive presidential assent. Constitutional amendments require a three-quarters majority, and certain entrenched provisions — including the electoral and 'best loser' arrangements — require both a three-quarters majority and, for some, a referendum.Bills pass three readings in both Houses and receive the Governor-General's assent. Constitutional amendments to entrenched provisions need a two-thirds majority in the House of Representatives and then approval by a referendum, a double lock that has defeated every reform package put to voters.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 professionA three-branch profession unusual in the region: barristers hold rights of audience, attorneys handle procedure and instruct barristers, and notaries deal with conveyancing and authenticated instruments under the civil-law tradition.A fused profession of legal practitioners admitted by the High Court under the Legal Profession Act, after a law degree and the Legal Education Certificate. The Grenada Bar Association represents practitioners.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 — the constitutional detail behind a one-line summary is often the part that governs the outcome.