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Comparison of selected legal systems
AttributeParaguayReviewedGrenadaReviewedBotswanaReviewedComorosReviewedBelizeReviewed
Legal familyCivil lawCommon lawMixed Roman-Dutch and English common lawMixed French civil law and Islamic lawCommon law
System of governmentUnitary presidential republicConstitutional monarchyParliamentary republicFederal presidential republicParliamentary constitutional monarchy
ConstitutionConstitution of the Republic of ParaguayThe Grenada ConstitutionConstitution of BotswanaConstitution of the Union of the ComorosBelize Constitution
In force since19921973196620011981
CapitalAsunciรณnSaint George'sGaboroneMoroniBelmopan
Official languagesSpanish, GuaranรญEnglishEnglish, SetswanaComorian, Arabic, FrenchEnglish, Spanish, Belize Kriol, Q'eqchi', Mopan
CurrencyParaguayan guaranรญ (PYG)East Caribbean dollar (XCD)Botswana pula (BWP)Comorian franc (KMF)Belize dollar (BZD)
Population6,900,000126,0002,680,000850,000410,000
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. The state comprises Grenada, Carriacou and Petite Martinique; Carriacou and Petite Martinique have a Ministry and local administration but no separate legislature.Unitary. Districts and sub-districts administer central policy, and the House of Chiefs (Ntlo ya Dikgosi) is an advisory chamber that must be consulted on bills affecting customary law, tribal organisation and tribal property.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, 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.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 are introduced in the National Assembly, take three readings with committee scrutiny between the second and third, and go to the President for assent. Bills affecting customary law, tribal property or the organisation of the tribes must first be referred to the Ntlo ya Dikgosi for its opinion, though that opinion does not bind the 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.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.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 admitted by the High Court after a recognised law degree and articles of pupillage; there is no split between advocates and attorneys, and the Law Society of Botswana regulates practice.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 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.