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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
AttributeOmanReviewedKuwaitReviewedMadagascarReviewed
Legal familyMixed (civil law and Islamic law)Mixed (civil law and Islamic law)French civil law with customary law
System of governmentUnitary absolute monarchyUnitary constitutional monarchySemi-presidential republic
ConstitutionBasic Law of the StateConstitution of the State of KuwaitConstitution of the Fourth Republic
In force since199619622010
CapitalMuscatKuwait CityAntananarivo
Official languagesArabicArabicMalagasy, French
CurrencyOmani rial (OMR)Kuwaiti dinar (KWD)Malagasy ariary (MGA)
Population4,600,0004,300,00030,300,000
Division of powersUnitary. Eleven governorates headed by appointed governors, with municipal councils holding advisory functions over local services. No legislative competence exists below the national level.Unitary. Six governorates administered by appointed governors, with no legislative competence.Unitary with a decentralised structure of 23 regions and communes. Successive constitutions have promised fuller decentralisation, including provincial autonomy, which has not been implemented.
How law is madeDraft legislation is prepared by ministries and the Council of Ministers, may be referred to the Council of Oman for review, and takes effect on the Sultan's signature and publication in the Official Gazette. The Majlis al-Shura may propose legislation and question ministers, and its role was modestly strengthened after 2011, but it cannot enact or block a royal decree.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 originate with the government or members of either chamber, are examined in committee, and must pass both the National Assembly and the Senate; the Assembly prevails on disagreement. The Haute Cour Constitutionnelle may review a law before promulgation, and organic laws must be referred to it as a matter of course.
Legal professionAdvocacy is regulated by the Ministry of Justice and Legal Affairs; Omani nationality is required for rights of audience, and foreign lawyers practise as consultants within licensed firms. Pleadings are in Arabic. Judges are appointed by royal decree on the recommendation of the Supreme Judicial Council. Notarisation is required for real property dispositions, and land registration is administered by the Ministry of Housing and Urban Planning.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.Avocats admitted to the Ordre des avocats de Madagascar after a law degree and professional training, alongside notaires for authenticated instruments and huissiers for service and enforcement — the standard French division of functions.

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.