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
Attribute	MonacoReviewed	FijiReviewed	MalaysiaReviewed
Legal family	Civil law	Common law with customary law	Mixed common law and Islamic law
System of government	Constitutional hereditary monarchy	Unitary parliamentary republic	Federal constitutional monarchy
Constitution	Constitution of the Principality of Monaco	Constitution of the Republic of Fiji	Federal Constitution of Malaysia
In force since	1962	2013	1957
Capital	Monaco	Suva	Kuala Lumpur
Official languages	French	English, Fijian, Fiji Hindi	Malay, English
Currency	Euro (EUR)	Fijian dollar (FJD)	Malaysian ringgit (MYR)
Population	39,000	930,000	34,100,000
Division of powers	A 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 Suprême acting as both constitutional and supreme administrative court.	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.	Federal, with 13 states and three federal territories. The Ninth Schedule sets out Federal, State and Concurrent Lists: land, Islamic law, Malay custom and local government are state matters, while trade, finance, defence and civil and criminal law are federal. Sabah and Sarawak hold additional competences — immigration, native customary land, and their own High Court — reflecting the terms on which they joined.
How law is made	A 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.	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.	Bills pass both houses; the Dewan Negara can delay but not block, and money bills originate in the Dewan Rakyat. Royal assent is required and, since a 1994 amendment, is deemed given after 30 days if withheld. Amendments affecting the rulers, the special position of the Malays, citizenship or the position of Sabah and Sarawak require additional consents beyond the two-thirds majority.
Legal profession	A small bar of avocats-défenseurs, 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.	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 fused profession of advocates and solicitors, but regulated separately by territory: the Malaysian Bar under the Legal Profession Act 1976 for Peninsular Malaysia, the Sabah Law Society, and the Advocates Association of Sarawak. Admission requires a recognised law degree or the Certificate in Legal Practice, pupillage of nine months, and admission by the High Court. Syariah practitioners are separately admitted by state Syariah authorities and require Syariah law qualifications.

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.