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Comparison of selected legal systems
AttributeParaguayReviewedComorosReviewedTongaReviewedCyprusReviewed
Legal familyCivil lawMixed French civil law and Islamic lawCommon law with customary lawMixed common law and civil law
System of governmentUnitary presidential republicFederal presidential republicConstitutional monarchyUnitary presidential republic
ConstitutionConstitution of the Republic of ParaguayConstitution of the Union of the ComorosAct of Constitution of TongaConstitution of the Republic of Cyprus
In force since1992200118751960
CapitalAsunciรณnMoroniNuku'alofaNicosia
Official languagesSpanish, GuaranรญComorian, Arabic, FrenchTongan, EnglishGreek, Turkish
CurrencyParaguayan guaranรญ (PYG)Comorian franc (KMF)Tongan paสปanga (TOP)Euro (EUR)
Population6,900,000850,000105,0001,260,000
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 districts administered centrally and elected municipalities. In practice the government exercises effective control over roughly the southern two-thirds of the island; the north has been separately administered since 1974 under an entity recognised only by Turkey, and the application of the EU acquis is suspended there under Protocol 10 to the Accession Treaty. The atlas describes the law of the Republic and notes where it is not effectively applied.
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 are introduced by ministers or members and passed by the House of Representatives. The President may return a law for reconsideration or refer it to the Supreme Court for a constitutionality ruling before promulgation; if the Court finds no conflict, promulgation follows. Laws enter into force on publication in the Official Gazette unless otherwise provided, and EU obligations are frequently implemented by harmonising statute and regulation.
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.A fused profession of advocates admitted under the Advocates Law after a law degree, the Legal Council examinations and a twelve-month pupillage, with compulsory membership of the Cyprus Bar Association. Many practitioners qualify in the United Kingdom or Greece, and English-language practice is standard in commercial work. Advocates hold a monopoly on court representation and on certifying company documents, and the profession is unusually large per head of population because of the international corporate and trusts business.

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.