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Comparison of selected legal systems
AttributeParaguayReviewedFijiReviewedGrenadaReviewedPalauReviewed
Legal familyCivil lawCommon law with customary lawCommon lawMixed common law with customary law
System of governmentUnitary presidential republicUnitary parliamentary republicConstitutional monarchyPresidential republic in free association with the United States
ConstitutionConstitution of the Republic of ParaguayConstitution of the Republic of FijiThe Grenada ConstitutionConstitution of the Republic of Palau
In force since1992201319731981
CapitalAsunciรณnSuvaSaint George'sNgerulmud
Official languagesSpanish, GuaranรญEnglish, Fijian, Fiji HindiEnglishPalauan, English
CurrencyParaguayan guaranรญ (PYG)Fijian dollar (FJD)East Caribbean dollar (XCD)United States dollar (USD)
Population6,900,000930,000126,00018,000
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 and deliberately centralised. Section 1 declares Fiji a sovereign state whose Parliament legislates for the whole country; there are no provinces with legislative power. The 14 provincial councils and the iTaukei Affairs Board administer indigenous affairs under the iTaukei Affairs Act. Rotuma has a distinct status under the Rotuma Act.Unitary. The state comprises Grenada, Carriacou and Petite Martinique; Carriacou and Petite Martinique have a Ministry and local administration but no separate legislature.A republic of sixteen states, each with its own constitution, governor and legislature, over a small population โ€” Palau has more layers of government per head than almost anywhere. The national Council of Chiefs, made up of the paramount chief of each state, advises the President on custom and traditional law, and the two highest-ranking chiefly titles of Koror and Melekeok carry particular weight.
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 are introduced in the unicameral Parliament, referred to a standing committee, and pass through second reading, committee and third reading before assent by the President. There is no upper house. A constitutional amendment requires the support of three-quarters of all members of Parliament and then approval by three-quarters of registered voters at a referendum, a threshold that has never been met.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.Bills must pass both the Senate and the House of Delegates and are then presented to the President, who may veto; Congress may override with a two-thirds vote of each chamber. Because the House gives every state one delegate regardless of population, the smallest states hold disproportionate weight in the second chamber. Constitutional amendments require a three-quarters vote of each house or a convention, followed by approval at referendum in a majority of the states.
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 fused profession under the Legal Practitioners Act 2009: practitioners are admitted by the Chief Justice as barristers and solicitors. Most qualify through the University of the South Pacific law degree followed by the Professional Diploma in Legal Practice. Admission and discipline are handled by the Chief Registrar and the Independent Legal Services Commission rather than by the Fiji Law Society, which is a voluntary professional body.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.Admission is to the Supreme Court under rules that recognise United States bar qualifications, and a substantial part of the bar and bench trained in the US. Palau also licenses trial assistants to appear in the Court of Common Pleas and the Land Court, which is how much routine representation is provided. Land Court practice is a specialism in itself, given the layers of Spanish, German, Japanese and Trust Territory administration that Palauan title claims have to be traced through.

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.