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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
AttributeMonacoReviewedVanuatuReviewedKuwaitReviewed
Legal familyCivil lawMixed common, civil and customary lawMixed (civil law and Islamic law)
System of governmentConstitutional hereditary monarchyUnitary parliamentary republicUnitary constitutional monarchy
ConstitutionConstitution of the Principality of MonacoConstitution of the Republic of VanuatuConstitution of the State of Kuwait
In force since196219801962
CapitalMonacoPort VilaKuwait City
Official languagesFrenchBislama, English, FrenchArabic
CurrencyEuro (EUR)Vanuatu vatu (VUV)Kuwaiti dinar (KWD)
Population39,000330,0004,300,000
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 decentralised administration. Six provinces โ€” Malampa, Penama, Sanma, Shefa, Tafea and Torba โ€” have councils under the Decentralisation Act with delegated functions. Custom land management is decentralised much further, to area-level Custom Land Tribunals and nakamal-based decision-making under the Custom Land Management Act 2013.Unitary. Six governorates administered by appointed governors, with no legislative competence.
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.Bills are read three times in the single chamber and assented to by the President, who may refer a bill to the Supreme Court if he considers it inconsistent with the Constitution. Ordinary bills need a simple majority of members present, with a quorum of two-thirds. Constitutional amendments require a two-thirds majority of all members; if the amendment touches the status of Bislama, English or French, land, or the republican form of the state, it must also be approved at a national 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).
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.A fused profession regulated by the Legal Practitioners Act: practitioners are admitted by the Chief Justice and licensed by the Law Council. The University of the South Pacific's law school is in Port Vila, so many Pacific lawyers train in Vanuatu. Practitioners may need to work in Bislama, English or French depending on the client and the court file, and the Public Solicitor is a constitutional office rather than a discretionary aid scheme.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.

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.