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Comparison

Read two legal systems against each other

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
AttributeParaguayReviewedGrenadaReviewedSenegalReviewedBahrainReviewed
Legal familyCivil lawCommon lawCivil law (French tradition)Mixed (civil law and Islamic law)
System of governmentUnitary presidential republicConstitutional monarchyUnitary presidential republicUnitary constitutional monarchy
ConstitutionConstitution of the Republic of ParaguayThe Grenada ConstitutionConstitution of the Republic of SenegalConstitution of the Kingdom of Bahrain
In force since1992197320012002
CapitalAsunciรณnSaint George'sDakarManama
Official languagesSpanish, GuaranรญEnglishFrench, Wolof, Pulaar, SererArabic
CurrencyParaguayan guaranรญ (PYG)East Caribbean dollar (XCD)West African CFA franc (XOF)Bahraini dinar (BHD)
Population6,900,000126,00017,700,0001,500,000
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.A strong executive presidency with a Prime Minister and Council of Ministers, a unicameral National Assembly, and a judiciary in which the Conseil constitutionnel, Cour suprรชme and Cour des comptes occupy separate apexes.Unitary. Four governorates administered centrally; elected municipal councils were abolished as a tier in 2014 and their functions transferred to the governorates.
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 originate with the government or deputies, are examined in committee and voted in plenary. The President promulgates within the constitutional period or refers the text to the Conseil constitutionnel.Bills require passage by both chambers. Where they disagree, a joint sitting decides by majority with the Speaker of the appointed Consultative Council presiding and casting the deciding vote, which structurally favours the appointed chamber. The King ratifies and promulgates; a returned bill requires a two-thirds majority of the joint Assembly to be re-enacted. Decree-laws may be issued between sessions and must be submitted to the Assembly afterwards.
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.Avocats are admitted to the Ordre des avocats du Sรฉnรฉgal after a law degree, the CFPA professional course and a traineeship. Notaires and huissiers are separate regulated professions.Advocates are licensed by the Ministry of Justice; Bahraini nationality is required for rights of audience before the higher courts, and foreign firms practise in association with local counsel. Bahrain is unusual in the region for the number of foreign firms permitted to advise, reflecting its role as a financial centre. Judges are appointed by royal order on the recommendation of the Supreme Judicial Council, and notarial authentication is required for property transfers and powers of attorney.

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.