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Comparison of selected legal systems
AttributeParaguayReviewedBruneiReviewedGrenadaReviewedBhutanReviewed
Legal familyCivil lawMixed common law and Islamic lawCommon lawMixed common law and Buddhist customary tradition
System of governmentUnitary presidential republicAbsolute monarchyConstitutional monarchyConstitutional monarchy
ConstitutionConstitution of the Republic of ParaguayConstitution of Brunei DarussalamThe Grenada ConstitutionConstitution of the Kingdom of Bhutan
In force since1992195919732008
CapitalAsunciรณnBandar Seri BegawanSaint George'sThimphu
Official languagesSpanish, GuaranรญMalay, EnglishEnglishDzongkha
CurrencyParaguayan guaranรญ (PYG)Brunei dollar (BND)East Caribbean dollar (XCD)Bhutanese ngultrum (BTN)
Population6,900,000450,000126,000787,000
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 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. The state comprises Grenada, Carriacou and Petite Martinique; Carriacou and Petite Martinique have a Ministry and local administration but no separate legislature.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.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.Bills pass three readings in both Houses and receive the Governor-General's assent. Constitutional amendments to entrenched provisions need a two-thirds majority in the House of Representatives and then approval by a referendum, a double lock that has defeated every reform package put to voters.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.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.A fused profession of legal practitioners admitted by the High Court under the Legal Profession Act, after a law degree and the Legal Education Certificate. The Grenada Bar Association represents practitioners.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.