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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
AttributeMonacoReviewedBruneiReviewedPanamaReviewed
Legal familyCivil lawMixed common law and Islamic lawCivil law
System of governmentConstitutional hereditary monarchyAbsolute monarchyUnitary presidential republic
ConstitutionConstitution of the Principality of MonacoConstitution of Brunei DarussalamPolitical Constitution of the Republic of Panama
In force since196219591972
CapitalMonacoBandar Seri BegawanPanama City
Official languagesFrenchMalay, EnglishSpanish
CurrencyEuro (EUR)Brunei dollar (BND)Balboa (US dollar in circulation) (PAB)
Population39,000450,0004,400,000
Division of powersA unitary state of about two square kilometres with a single commune. Legislative power is exercised jointly by the Prince and the National Council; executive power belongs to the Prince, exercised through the Minister of State and the Government Council; judicial power is delegated by the Prince to the courts, with the Tribunal Suprรชme acting as both constitutional and supreme administrative court.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.Unitary, with ten provinces and five indigenous comarcas. The comarcas โ€” Guna Yala, Emberรก-Wounaan, Ngรคbe-Buglรฉ, Guna de Madugandรญ and Guna de Wargandรญ โ€” hold recognised collective land title and internal authority.
How law is madeA bill may be initiated by the Prince or proposed by the National Council. Government bills are laid before the Council, examined in committee and voted; adoption requires the agreement of both the Prince and the Council. The Prince then promulgates the law by sovereign ordinance and it is published in the Journal de Monaco.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.Bills receive three debates in the National Assembly. The President may object in whole or in part; the Assembly insists with a two-thirds vote, after which the President must promulgate unless the objection was constitutional, in which case the Supreme Court decides.
Legal professionA small bar of avocats-dรฉfenseurs, avocats and avocats stagiaires, organised as the Ordre des Avocats, with admission requiring Monegasque nationality preference, a law degree and a traineeship. French avocats may appear in specified circumstances. Notaries are appointed by sovereign ordinance and are few in number.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 โ€” a few hundred practitioners โ€” 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.Practice requires a Panamanian law degree and a licence from the Supreme Court; the Colegio Nacional de Abogados is influential but membership is voluntary. Only Panamanian lawyers may appear in court, which is why offshore work is routinely structured through local counsel.

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.