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.
Select up to six documented jurisdictions
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| Attribute | MoroccoReviewed | BruneiReviewed | CubaReviewed |
|---|---|---|---|
| Legal family | Civil law with Islamic law in personal status | Mixed common law and Islamic law | Socialist civil law |
| System of government | Constitutional monarchy | Absolute monarchy | One-party socialist republic |
| Constitution | Constitution of the Kingdom of Morocco | Constitution of Brunei Darussalam | Constituciรณn de la Repรบblica de Cuba |
| In force since | 2011 | 1959 | 2019 |
| Capital | Rabat | Bandar Seri Begawan | Havana |
| Official languages | Arabic, Tamazight | Malay, English | Spanish |
| Currency | Moroccan dirham (MAD) | Brunei dollar (BND) | Cuban peso (CUP) |
| Population | 37,500,000 | 450,000 | 11,200,000 |
| Division of powers | Unitary but substantially regionalised since 2015, with twelve regions holding directly elected councils and their own budgets under the advanced regionalisation programme. Regions have executive competences in development planning and transport; they do not legislate. | 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, organised on the principle of a single system of state power. The 2019 Constitution and the 2019 territorial reform recognise 15 provinces and the special municipality of Isla de la Juventud, with provincial governors appointed on the President's nomination. |
| How law is made | Bills may be introduced by the head of government or by members of either chamber. They pass through committee and plenary in both houses, with the House of Representatives having the final word where the chambers disagree. Organic laws must be referred to the Constitutional Court before promulgation. The King promulgates statutes by dahir within thirty days, and may ask parliament to reconsider a bill or submit it to referendum. | 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. | Legislative initiative lies with deputies, the Council of State, the Council of Ministers, the courts, the Prosecutor General, mass organisations and 10,000 citizens by popular initiative. The Assembly meets in short ordinary sessions, so much law is made by decree-law of the Council of State and subsequently ratified. Constitutional amendment requires two-thirds of the Assembly, and a referendum for provisions on the political system or rights. |
| Legal profession | Avocats are admitted to one of the regional bars and organised nationally through the Association des Barreaux du Maroc; practice before the Court of Cassation requires additional seniority. Notaries and adouls coexist โ the notaire handles conveyancing and company documents in the French tradition, while the adoul draws up marriage and inheritance instruments under Islamic law. Judges are career appointments trained at the Institut Supรฉrieur de la Magistrature. | 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. | Practising litigators generally work through the Organizaciรณn Nacional de Bufetes Colectivos, a self-financing national body of collective law offices; independent private practice is not a recognised route. Membership of the Uniรณn Nacional de Juristas de Cuba is the professional association. Notarial functions are performed by state notaries. |
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.