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Comparison

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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
AttributeParaguayReviewedDR CongoReviewedKuwaitReviewedMadagascarReviewed
Legal familyCivil lawCivil law (Belgian tradition)Mixed (civil law and Islamic law)French civil law with customary law
System of governmentUnitary presidential republicUnitary semi-presidential republicUnitary constitutional monarchySemi-presidential republic
ConstitutionConstitution of the Republic of ParaguayConstitution of the Democratic Republic of the CongoConstitution of the State of KuwaitConstitution of the Fourth Republic
In force since1992200619622010
CapitalAsunciรณnKinshasaKuwait CityAntananarivo
Official languagesSpanish, GuaranรญFrench, Lingala, Swahili, Kikongo, TshilubaArabicMalagasy, French
CurrencyParaguayan guaranรญ (PYG)Congolese Franc (CDF)Kuwaiti dinar (KWD)Malagasy ariary (MGA)
Population6,900,000102,300,0004,300,00030,300,000
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.Semi-presidential: a directly elected President, a Prime Minister from the parliamentary majority, and a bicameral Parliament. The 2006 constitution split the former Supreme Court into three separate apex courts.Unitary. Six governorates administered by appointed governors, with no legislative competence.Unitary with a decentralised structure of 23 regions and communes. Successive constitutions have promised fuller decentralisation, including provincial autonomy, which has not been implemented.
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 pass both chambers; persistent disagreement is resolved by a joint commission or a final National Assembly vote. The President promulgates within the constitutional period, and the Constitutional Court may be seised beforehand.Under the constitution as designed, bills passed by the National Assembly required Emiri sanction, and the Emir could return a bill for reconsideration which the Assembly could override by a two-thirds majority. With the Assembly dissolved and the relevant articles suspended since May 2024, legislation is made by Emiri decree on the proposal of the Council of Ministers and published in the Official Gazette (Kuwait Al-Youm).Bills originate with the government or members of either chamber, are examined in committee, and must pass both the National Assembly and the Senate; the Assembly prevails on disagreement. The Haute Cour Constitutionnelle may review a law before promulgation, and organic laws must be referred to it as a matter of course.
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.Avocats admitted to provincial bars under the national Ordre des avocats after a law degree and traineeship; dรฉfenseurs judiciaires assist in lower courts.Advocacy is reserved to Kuwaiti nationals enrolled with the Ministry of Justice and the Kuwait Bar Association, with foreign lawyers acting as consultants and unable to appear; pleadings are in Arabic. Judges are appointed by the Supreme Judicial Council, and a significant proportion of the bench has historically been seconded from other Arab states. Notarial authentication at the Ministry of Justice is required for powers of attorney, property transfers and company formation documents.Avocats admitted to the Ordre des avocats de Madagascar after a law degree and professional training, alongside notaires for authenticated instruments and huissiers for service and enforcement โ€” the standard French division of functions.

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.