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Comparison of selected legal systems
AttributeParaguayReviewedComorosReviewedChileReviewedMaldivesReviewed
Legal familyCivil lawMixed French civil law and Islamic lawCivil lawMixed Islamic and common law
System of governmentUnitary presidential republicFederal presidential republicUnitary presidential republicPresidential republic
ConstitutionConstitution of the Republic of ParaguayConstitution of the Union of the ComorosPolitical Constitution of the Republic of ChileConstitution of the Republic of Maldives
In force since1992200119802008
CapitalAsunciรณnMoroniSantiagoMalรฉ
Official languagesSpanish, GuaranรญComorian, Arabic, FrenchSpanishDhivehi
CurrencyParaguayan guaranรญ (PYG)Comorian franc (KMF)Chilean peso (CLP)Maldivian rufiyaa (MVR)
Population6,900,000850,00019,600,000521,000
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.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. Sixteen regions administer but do not legislate. Regional governors have been directly elected since 2021, which shifted real power away from the centrally appointed delegates, but legislative competence remains exclusively national.Unitary with a decentralised layer under the Decentralisation Act 2010: 21 atolls with elected atoll councils, plus island and city councils. Councils have limited revenue-raising and service delivery functions; the geography of roughly 190 inhabited islands makes administrative decentralisation a practical necessity rather than a constitutional division of sovereignty.
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 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 originate with the President or in either chamber, though tax, budget and social-security bills are the President's exclusive initiative โ€” an unusually strong executive agenda power. Both chambers must approve; a mixed committee resolves conflict. The President may veto, overridden by two-thirds. Constitutional amendment needs four-sevenths of sitting members, with two-thirds for certain entrenched chapters.Bills pass the Majlis by simple majority and go to the President, who may assent or return the bill once; a second passage requires assent. The Attorney General advises on constitutionality, and the Supreme Court may rule on it after enactment. Constitutional amendments need a two-thirds majority, and amendments to specified provisions also require a public 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.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.A five-year degree, a supervised practice period, and admission by the Supreme Court itself, which is unusual โ€” the Court, not a bar, confers the title of abogado. Membership of the Colegio de Abogados has been voluntary since 1981, so the Court retains disciplinary jurisdiction over misconduct.Lawyers are licensed and regulated by the Maldives Bar Council, established under the Legal Profession Act 2019 โ€” before which licensing sat with the Attorney General's office and then the Department of Judicial Administration. A recognised law degree, the Bar examination and a period of training are required, and licences are tiered by the level of court in which the lawyer may appear.

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.