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Comparison of selected legal systems
AttributeParaguayReviewedCubaReviewedComorosReviewedGrenadaReviewedBelizeReviewed
Legal familyCivil lawSocialist civil lawMixed French civil law and Islamic lawCommon lawCommon law
System of governmentUnitary presidential republicOne-party socialist republicFederal presidential republicConstitutional monarchyParliamentary constitutional monarchy
ConstitutionConstitution of the Republic of ParaguayConstituciรณn de la Repรบblica de CubaConstitution of the Union of the ComorosThe Grenada ConstitutionBelize Constitution
In force since19922019200119731981
CapitalAsunciรณnHavanaMoroniSaint George'sBelmopan
Official languagesSpanish, GuaranรญSpanishComorian, Arabic, FrenchEnglishEnglish, Spanish, Belize Kriol, Q'eqchi', Mopan
CurrencyParaguayan guaranรญ (PYG)Cuban peso (CUP)Comorian franc (KMF)East Caribbean dollar (XCD)Belize dollar (BZD)
Population6,900,00011,200,000850,000126,000410,000
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.Unitary, organised on the principle of a single system of state power. The 2019 Constitution and the 2019 territorial reform recognise 15 provinces and the special municipality of Isla de la Juventud, with provincial governors appointed on the President's nomination.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 state comprises Grenada, Carriacou and Petite Martinique; Carriacou and Petite Martinique have a Ministry and local administration but no separate legislature.Unitary, with six districts and elected town and village councils. Maya communal land rights in Toledo are recognised through the courts rather than by statute, and implementation is supervised by the CCJ.
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.Legislative initiative lies with deputies, the Council of State, the Council of Ministers, the courts, the Prosecutor General, mass organisations and 10,000 citizens by popular initiative. The Assembly meets in short ordinary sessions, so much law is made by decree-law of the Council of State and subsequently ratified. Constitutional amendment requires two-thirds of the Assembly, and a referendum for provisions on the political system or rights.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 both Houses and receive the Governor-General's assent. Constitutional amendments to entrenched provisions need a two-thirds majority in the House of Representatives and then approval by a referendum, a double lock that has defeated every reform package put to voters.A bill passes three readings in the House of Representatives, then the Senate, and receives the Governor-General's assent. Money bills originate in the House. Constitutional amendments need a two-thirds majority of all House members, and certain entrenched provisions require three-quarters.
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.Practising litigators generally work through the Organizaciรณn Nacional de Bufetes Colectivos, a self-financing national body of collective law offices; independent private practice is not a recognised route. Membership of the Uniรณn Nacional de Juristas de Cuba is the professional association. Notarial functions are performed by state notaries.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 of legal practitioners admitted by the High Court under the Legal Profession Act, after a law degree and the Legal Education Certificate. The Grenada Bar Association represents practitioners.A fused profession of attorneys-at-law admitted by the High Court under the Legal Profession Act, with the Bar Association of Belize exercising disciplinary functions. Commonwealth qualifications are recognised on application, which keeps a small bar workable.

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.