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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
AttributeMauritiusReviewedKuwaitReviewedIranReviewed
Legal familyMixed French civil law and English common lawMixed (civil law and Islamic law)Islamic law with civil law codification
System of governmentParliamentary republicUnitary constitutional monarchyIslamic republic
ConstitutionConstitution of MauritiusConstitution of the State of KuwaitConstitution of the Islamic Republic of Iran
In force since196819621979
CapitalPort LouisKuwait CityTehran
Official languagesEnglish, French, Mauritian CreoleArabicPersian
CurrencyMauritian rupee (MUR)Kuwaiti dinar (KWD)Rial (IRR)
Population1,260,0004,300,00089,000,000
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. Six governorates administered by appointed governors, with no legislative competence.Unitary, with 31 provinces headed by governors-general appointed by the Interior Ministry, alongside elected city and village councils created by the Constitution and operating since 1999 with limited competences.
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.Under the constitution as designed, bills passed by the National Assembly required Emiri sanction, and the Emir could return a bill for reconsideration which the Assembly could override by a two-thirds majority. With the Assembly dissolved and the relevant articles suspended since May 2024, legislation is made by Emiri decree on the proposal of the Council of Ministers and published in the Official Gazette (Kuwait Al-Youm).A bill is introduced by the Government or by at least fifteen deputies, passes the Majlis, and goes to the Guardian Council, which has ten days, extendable, to find it consistent with Islam and the Constitution. If the Council objects, the bill returns for amendment; persistent disagreement goes to the Expediency Discernment Council, whose decision is final. Only then does the President sign and publish.
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.Advocacy is reserved to Kuwaiti nationals enrolled with the Ministry of Justice and the Kuwait Bar Association, with foreign lawyers acting as consultants and unable to appear; pleadings are in Arabic. Judges are appointed by the Supreme Judicial Council, and a significant proportion of the bench has historically been seconded from other Arab states. Notarial authentication at the Ministry of Justice is required for powers of attorney, property transfers and company formation documents.Two parallel routes to practice, which is unusual and consequential: attorneys licensed by the Iranian Bar Association (Kanoon-e Vokala), a self-governing body dating to 1953, and attorneys licensed under Article 187 of the Third Development Plan directly by the judiciary. The two groups have contested each other's standing for two decades. Notaries operate licensed offices under the registration organisation, and their authentication is required for property transfers, marriage contracts and powers of attorney.

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.