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Comparison of selected legal systems
AttributeParaguayReviewedComorosReviewedNepalReviewedMoroccoReviewed
Legal familyCivil lawMixed French civil law and Islamic lawMixed common law and Hindu customary traditionCivil law with Islamic law in personal status
System of governmentUnitary presidential republicFederal presidential republicFederal parliamentary republicConstitutional monarchy
ConstitutionConstitution of the Republic of ParaguayConstitution of the Union of the ComorosConstitution of NepalConstitution of the Kingdom of Morocco
In force since1992200120152011
CapitalAsunciรณnMoroniKathmanduRabat
Official languagesSpanish, GuaranรญComorian, Arabic, FrenchNepaliArabic, Tamazight
CurrencyParaguayan guaranรญ (PYG)Comorian franc (KMF)Nepalese rupee (NPR)Moroccan dirham (MAD)
Population6,900,000850,00030,500,00037,500,000
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.Federal with three tiers: one federal government, seven provinces and 753 local units, each with its own elected assembly and schedule of exclusive powers. This is a genuine constitutional division rather than delegation โ€” local units have taxing and legislative competence โ€” and much post-2015 litigation concerns the boundaries between tiers and the slow transfer of staff and revenue.Unitary but substantially regionalised since 2015, with twelve regions holding directly elected councils and their own budgets under the advanced regionalisation programme. Regions have executive competences in development planning and transport; they do not legislate.
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 pass both federal houses, except money bills which originate in the House of Representatives; the President must assent. Constitutional amendment requires a two-thirds majority in both houses and, where a provision affects provincial boundaries or powers, the consent of a majority of provincial assemblies. Provinces and local units legislate within their own schedules.Bills may be introduced by the head of government or by members of either chamber. They pass through committee and plenary in both houses, with the House of Representatives having the final word where the chambers disagree. Organic laws must be referred to the Constitutional Court before promulgation. The King promulgates statutes by dahir within thirty days, and may ask parliament to reconsider a bill or submit it to 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.Advocates are licensed by the Nepal Bar Council after a law degree and the Council's examination, with tiers of pleader, advocate and senior advocate. A single licence permits appearance at all levels, and the Nepal Bar Association is the professional body. Legal aid is provided under the Legal Aid Act 1997 through district committees, and the Constitution guarantees free legal aid to indigent parties.Avocats are admitted to one of the regional bars and organised nationally through the Association des Barreaux du Maroc; practice before the Court of Cassation requires additional seniority. Notaries and adouls coexist โ€” the notaire handles conveyancing and company documents in the French tradition, while the adoul draws up marriage and inheritance instruments under Islamic law. Judges are career appointments trained at the Institut Supรฉrieur de la Magistrature.

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.