Comparison

Read two legal systems against each other

Because every portal follows the same fifteen-section outline, the comparison is genuinely like-for-like rather than a collage of whatever each government happens to publish.

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Comparison of selected legal systems
Attribute	ParaguayReviewed	ComorosReviewed	SamoaReviewed	KenyaReviewed
Legal family	Civil law	Mixed French civil law and Islamic law	Common law with customary law	Mixed (common law, customary law, Islamic law)
System of government	Unitary presidential republic	Federal presidential republic	Unitary parliamentary republic	Unitary presidential republic with devolved counties
Constitution	Constitution of the Republic of Paraguay	Constitution of the Union of the Comoros	Constitution of the Independent State of Samoa	Constitution of Kenya
In force since	1992	2001	1962	2010
Capital	Asunción	Moroni	Apia	Nairobi
Official languages	Spanish, Guaraní	Comorian, Arabic, French	Samoan, English	English, Swahili
Currency	Paraguayan guaraní (PYG)	Comorian franc (KMF)	Samoan tālā (WST)	Kenyan Shilling (KES)
Population	6,900,000	850,000	220,000	55,100,000
Division of powers	Unitary 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 Mohéli 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. Parliament legislates for the whole country. Below it, about 250 villages govern themselves through the village fono (council of matai) under the Village Fono Act 1990, which gives customary village authority statutory recognition — a genuine layer of local government rather than a delegation of central power.	Presidential system with no Prime Minister, a bicameral Parliament of National Assembly and Senate, 47 county governments with their own assemblies and executives, and an independent judiciary supervised by the Judicial Service Commission.
How law is made	Bills 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 are read three times in the Legislative Assembly, usually with parliamentary committee scrutiny, and are then assented to by the O le Ao o le Malo. Ordinary bills need a simple majority. Constitutional amendments require a two-thirds majority of all members at the third reading, and any amendment affecting customary land or matai titles is politically entrenched by the strength of the fa'a Samoa consensus even where the two-thirds threshold is met.	Bills are read three times with committee scrutiny and public participation, which the courts treat as a justiciable requirement. Bills concerning counties must pass both chambers. The President assents or refers the bill back with reservations, which Parliament may override by two-thirds.
Legal profession	A 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 Guaraní are official, courts must provide interpretation, and practitioners outside Asunción 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 fused profession under the Lawyers and Legal Practice Act 2014: lawyers are admitted by the Supreme Court and must hold a practising certificate from the Samoa Law Society. Most qualify at the University of the South Pacific or in New Zealand. Practice before the Land and Titles Court is different in character from ordinary litigation, because the issues are matai genealogy and customary entitlement rather than statutory or common-law rights.	Fused: an LLB, the Kenya School of Law advocates training programme, and admission by the Chief Justice produce an advocate of the High Court. The Law Society of Kenya is the professional body; Senior Counsel is the senior rank.

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 — the constitutional detail behind a one-line summary is often the part that governs the outcome.