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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
AttributeMonacoReviewedKuwaitReviewedKenyaReviewed
Legal familyCivil lawMixed (civil law and Islamic law)Mixed (common law, customary law, Islamic law)
System of governmentConstitutional hereditary monarchyUnitary constitutional monarchyUnitary presidential republic with devolved counties
ConstitutionConstitution of the Principality of MonacoConstitution of the State of KuwaitConstitution of Kenya
In force since196219622010
CapitalMonacoKuwait CityNairobi
Official languagesFrenchArabicEnglish, Swahili
CurrencyEuro (EUR)Kuwaiti dinar (KWD)Kenyan Shilling (KES)
Population39,0004,300,00055,100,000
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. Six governorates administered by appointed governors, with no legislative competence.Presidential system with no Prime Minister, a bicameral Parliament of National Assembly and Senate, 47 county governments with their own assemblies and executives, and an independent judiciary supervised by the Judicial Service Commission.
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.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).Bills are read three times with committee scrutiny and public participation, which the courts treat as a justiciable requirement. Bills concerning counties must pass both chambers. The President assents or refers the bill back with reservations, which Parliament may override by two-thirds.
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.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.Fused: an LLB, the Kenya School of Law advocates training programme, and admission by the Chief Justice produce an advocate of the High Court. The Law Society of Kenya is the professional body; Senior Counsel is the senior rank.

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.