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Comparison

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Comparison of selected legal systems
AttributeParaguayReviewedAlgeriaReviewedLesothoReviewedBhutanReviewed
Legal familyCivil lawCivil law with Islamic law in personal statusMixed Roman-Dutch and English common lawMixed common law and Buddhist customary tradition
System of governmentUnitary presidential republicSemi-presidential republicParliamentary constitutional monarchyConstitutional monarchy
ConstitutionConstitution of the Republic of ParaguayConstitution of the People's Democratic Republic of AlgeriaConstitution of LesothoConstitution of the Kingdom of Bhutan
In force since1992202019932008
CapitalAsunciรณnAlgiersMaseruThimphu
Official languagesSpanish, GuaranรญArabic, TamazightSesotho, EnglishDzongkha
CurrencyParaguayan guaranรญ (PYG)Algerian dinar (DZD)Lesotho loti (LSL)Bhutanese ngultrum (BTN)
Population6,900,00045,600,0002,300,000787,000
Division of powersUnitary with seventeen departments and the capital district, each with an elected governor and departmental board holding administrative and limited fiscal competence. Legislative power is national.Unitary, with 58 wilayas headed by walis appointed by the President alongside elected wilaya assemblies, and communes below them. Local bodies administer central policy and hold limited own-source revenue; they do not legislate.Unitary with ten districts, and a recognised hierarchy of chiefs exercising customary functions over land allocation and local dispute resolution. The Senate includes the twenty-two principal chiefs ex officio.Unitary with constitutionally entrenched local government: 20 dzongkhags, each with an elected Dzongkhag Tshogdu, plus gewog and thromde councils. Article 22 requires devolution of power to elected local governments, and local bodies have defined planning and revenue functions.
How law is madeBills may start in either chamber and must pass both. The President may object in whole or part; Congress overcomes an objection by absolute majority in both chambers. Constitutional amendment requires a two-thirds vote of each chamber and ratification by referendum; wholesale reform requires a constituent assembly.Bills come from the government or from at least twenty members of either chamber. They are examined in committee, passed by the People's National Assembly and then the Council of the Nation, with a joint commission resolving disagreement. Organic laws require an absolute majority in the lower house and a three-quarters majority in the upper, plus mandatory constitutional review. The President promulgates within thirty days and may seek a second reading requiring a two-thirds majority to overcome.Bills pass three readings in the National Assembly, go to the Senate for review, and receive royal assent. The Senate can delay but not indefinitely block ordinary bills. Amendments to entrenched constitutional provisions require a two-thirds majority and, for the most protected clauses, a referendum.Bills pass both houses; disagreement goes to a joint sitting. The King grants assent, and if he withholds it the bill returns to a joint sitting where a two-thirds majority carries it. Money bills originate in the National Assembly. Constitutional amendment requires a three-quarters majority of a joint sitting and, if the King so directs, a national referendum.
Legal professionA law degree and registration of the title with the Supreme Court, which maintains the roll and exercises discipline. Bar membership is voluntary. Because both Spanish and Guaranรญ are official, courts must provide interpretation, and practitioners outside Asunciรณn are commonly bilingual.Avocats are admitted through regional bars coordinated by the Union Nationale des Ordres des Avocats, with separate accreditation required for appearance before the Supreme Court and Council of State. Judges and prosecutors form a single career magistracy trained at the ร‰cole Supรฉrieure de la Magistrature. Notaries and bailiffs are regulated public officers in the French tradition, and notarial deeds are compulsory for real-property transfers.A split profession in form โ€” advocates and attorneys are separately admitted under the Legal Practitioners Act โ€” though in practice many practitioners hold both admissions; the Law Society of Lesotho regulates the attorneys' branch.Regulated by the Bhutan National Legal Institute and the Jabmi Tshogdey (Bar Council) under the Jabmi Act. Practitioners, called jabmis, require a law degree โ€” historically obtained in India โ€” and a licence; the Jigme Singye Wangchuck School of Law in Thimphu graduated its first cohort in 2022, so domestic legal education is very new. The profession is small, numbering a few hundred licensed practitioners.

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.