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Comparison of selected legal systems
AttributeParaguayReviewedGrenadaReviewedBhutanReviewedMoroccoReviewed
Legal familyCivil lawCommon lawMixed common law and Buddhist customary traditionCivil law with Islamic law in personal status
System of governmentUnitary presidential republicConstitutional monarchyConstitutional monarchyConstitutional monarchy
ConstitutionConstitution of the Republic of ParaguayThe Grenada ConstitutionConstitution of the Kingdom of BhutanConstitution of the Kingdom of Morocco
In force since1992197320082011
CapitalAsunciรณnSaint George'sThimphuRabat
Official languagesSpanish, GuaranรญEnglishDzongkhaArabic, Tamazight
CurrencyParaguayan guaranรญ (PYG)East Caribbean dollar (XCD)Bhutanese ngultrum (BTN)Moroccan dirham (MAD)
Population6,900,000126,000787,00037,500,000
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. The state comprises Grenada, Carriacou and Petite Martinique; Carriacou and Petite Martinique have a Ministry and local administration but no separate legislature.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.Unitary but substantially regionalised since 2015, with twelve regions holding directly elected councils and their own budgets under the advanced regionalisation programme. Regions have executive competences in development planning and transport; they do not legislate.
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 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 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.Bills may be introduced by the head of government or by members of either chamber. They pass through committee and plenary in both houses, with the House of Representatives having the final word where the chambers disagree. Organic laws must be referred to the Constitutional Court before promulgation. The King promulgates statutes by dahir within thirty days, and may ask parliament to reconsider a bill or submit it to 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 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.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.Avocats are admitted to one of the regional bars and organised nationally through the Association des Barreaux du Maroc; practice before the Court of Cassation requires additional seniority. Notaries and adouls coexist โ€” the notaire handles conveyancing and company documents in the French tradition, while the adoul draws up marriage and inheritance instruments under Islamic law. Judges are career appointments trained at the Institut Supรฉrieur de la Magistrature.

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.