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Comparison of selected legal systems
AttributeParaguayReviewedComorosReviewedTongaReviewedBhutanReviewed
Legal familyCivil lawMixed French civil law and Islamic lawCommon law with customary lawMixed common law and Buddhist customary tradition
System of governmentUnitary presidential republicFederal presidential republicConstitutional monarchyConstitutional monarchy
ConstitutionConstitution of the Republic of ParaguayConstitution of the Union of the ComorosAct of Constitution of TongaConstitution of the Kingdom of Bhutan
In force since1992200118752008
CapitalAsunciรณnMoroniNuku'alofaThimphu
Official languagesSpanish, GuaranรญComorian, Arabic, FrenchTongan, EnglishDzongkha
CurrencyParaguayan guaranรญ (PYG)Comorian franc (KMF)Tongan paสปanga (TOP)Bhutanese ngultrum (BTN)
Population6,900,000850,000105,000787,000
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.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. The Legislative Assembly legislates for the whole kingdom, and the island divisions of Tongatapu, Vava'u, Ha'apai, 'Eua and the Niuas are administrative districts headed by governors. Below that, town and district officers are elected under the Fakafekau'aki and District and Town Officers Act.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.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 three readings in the Legislative Assembly and require the King's assent, which is a real rather than purely formal step. Ordinary bills need a simple majority. Amendments to the Constitution require a majority in the Assembly at three separate readings and the consent of the King and Privy Council, and clause 79 forbids any amendment affecting the law of liberty, the succession to the throne or the titles and hereditary estates of the nobles.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.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.Law practitioners are admitted by the Chief Justice and licensed under the Law Practitioners Act, with the Tonga Law Society as the professional body. Most qualify overseas or at the University of the South Pacific. A practitioner working on land must know the Land Act's allotment system rather than general property law, because the constitutional bar on selling land means conveyancing in the ordinary sense does not exist.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.