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Comparison of selected legal systems
AttributeParaguayReviewedCanadaReviewedLibyaIndexedComorosReviewedIndonesiaReviewed
Legal familyCivil lawBijural: common law and Quรฉbec civil lawCivil law with Islamic law as a sourceMixed French civil law and Islamic lawMixed civil, customary and Islamic law
System of governmentUnitary presidential republicFederal parliamentary constitutional monarchyProvisional government with contested authorityFederal presidential republicPresidential republic
ConstitutionConstitution of the Republic of ParaguayConstitution Acts, 1867 and 1982Constitutional Declaration (interim)Constitution of the Union of the ComorosConstitution of the Republic of Indonesia 1945
In force since19921982201120011945
CapitalAsunciรณnOttawaTripoliMoroniJakarta
Official languagesSpanish, GuaranรญEnglish, FrenchArabicComorian, Arabic, FrenchIndonesian
CurrencyParaguayan guaranรญ (PYG)Canadian Dollar (CAD)Libyan dinar (LYD)Comorian franc (KMF)Indonesian rupiah (IDR)
Population6,900,00041,200,0006,900,000850,000281,600,000
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.Sections 91 and 92 divide federal and provincial competence. Section 33 allows a legislature to override certain Charter rights for renewable five-year periods.Nominally unitary with governorates and municipalities. In practice authority is divided between competing administrations and local armed actors, and municipal councils have in many places become the most functional layer of government.Federal. Grande Comore, Anjouan and Mohรฉli each have a governor and their own assembly with substantial autonomy over local administration, while the Union handles defence, currency, foreign affairs and nationality.Unitary but heavily decentralised since the 1999 regional autonomy laws, which devolved most service delivery to some 500 regencies and cities rather than to the 38 provinces. Aceh, Papua and its successor provinces, Yogyakarta and Jakarta hold special autonomy statuses with distinct arrangements โ€” Aceh includes Sharia jurisdiction and its own political parties; Yogyakarta's governor is hereditary.
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.Three readings plus committee study in each chamber, then Royal Assent. Money bills must originate in the Commons.There is no single functioning legislative process. The House of Representatives passes laws that the High Council of State contests, and the rival administrations issue decrees within their areas of control. Whether a given instrument is law therefore depends on which authority is recognised, which is exactly why this profile is marked as requiring research rather than described as settled.Bills originate with the government or members of the Assembly of the Union, are examined in committee and passed by the Assembly, then promulgated by the President. Matters within island competence are legislated by the island assemblies, and disputes over the boundary between Union and island competence are a standing feature of Comorian constitutional practice.Bills may originate with the DPR, the President or the DPD on regional matters, and require the agreement of both the DPR and the President โ€” a genuine joint enactment rather than assent. Once approved the President promulgates; if he does not, the bill becomes law after 30 days. The Constitutional Court may then annul it. The 2020 Job Creation Law was found conditionally unconstitutional for defective process, which forced the enactment of a new law on legislative drafting.
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.Provincial law societies regulate admission: an accredited degree, articles, and bar admission courses. Quรฉbec has separate avocat and notaire professions.Advocates are admitted through the Libyan Bar Association, and the profession has continued to function, including in human-rights litigation, despite serious risks to practitioners. Judicial appointments run through the Supreme Judicial Council. Reliable current information on admission requirements and numbers is limited, which is reflected in the verification status of this entry.A small bar of avocats admitted after French-model legal training, supplemented by qadis who require religious-law qualification for the personal-status jurisdiction; many practitioners train in France or Madagascar.Advocates are admitted under the Advocate Law 2003 after a law degree, a professional course, the bar examination and two years' apprenticeship, then sworn in by a High Court. PERADI is the principal bar association, though the profession has been divided by competing organisations, and the Constitutional Court has held that multiple bars may coexist while a single body administers admission. Notaries are a separate regulated profession with exclusive competence over deeds of incorporation and land transfers.

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.