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Comparison of selected legal systems
AttributeParaguayReviewedGrenadaReviewedIraqReviewedComorosReviewed
Legal familyCivil lawCommon lawCivil law with Islamic law influenceMixed French civil law and Islamic law
System of governmentUnitary presidential republicConstitutional monarchyFederal parliamentary republicFederal presidential republic
ConstitutionConstitution of the Republic of ParaguayThe Grenada ConstitutionConstitution of the Republic of IraqConstitution of the Union of the Comoros
In force since1992197320052001
CapitalAsunciรณnSaint George'sBaghdadMoroni
Official languagesSpanish, GuaranรญEnglishArabic, KurdishComorian, Arabic, French
CurrencyParaguayan guaranรญ (PYG)East Caribbean dollar (XCD)Iraqi dinar (IQD)Comorian franc (KMF)
Population6,900,000126,00045,500,000850,000
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.Genuinely federal in form: 15 governorates not organised into a region, plus the Kurdistan Region, which has its own Parliament, government, judiciary and security forces. Governorates may petition to form new regions. Residual powers lie with the regions and governorates rather than the centre, and regional law prevails over federal law outside the exclusive federal competences โ€” the reverse of the usual federal rule.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.
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 proposed by the President with the Council of Ministers, or by ten members or a committee of the Council of Representatives. They pass two readings and a vote, and the President ratifies within fifteen days, after which they are published and take effect. The Federation Council envisaged by the Constitution has never been created, so there is no second chamber in practice.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.
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.Lawyers are admitted by the Iraqi Bar Association under the Advocacy Law, with grades of practice determining which courts a member may appear in โ€” a seniority ladder rather than a single right of audience. The Bar is self-governing and its licence is required for court work. The Kurdistan Region has its own bar association, and the two are administratively distinct, so practitioners generally hold the licence appropriate to where they appear.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 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.