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Comparison of selected legal systems
AttributeParaguayReviewedGuyanaReviewedUruguayReviewedLesothoReviewedComorosReviewed
Legal familyCivil lawMixed common and civil lawCivil lawMixed Roman-Dutch and English common lawMixed French civil law and Islamic law
System of governmentUnitary presidential republicUnitary presidential republicUnitary presidential republicParliamentary constitutional monarchyFederal presidential republic
ConstitutionConstitution of the Republic of ParaguayConstitution of the Co-operative Republic of GuyanaConstitution of the Oriental Republic of UruguayConstitution of LesothoConstitution of the Union of the Comoros
In force since19921980196719932001
CapitalAsunciรณnGeorgetownMontevideoMaseruMoroni
Official languagesSpanish, GuaranรญEnglishSpanishSesotho, EnglishComorian, Arabic, French
CurrencyParaguayan guaranรญ (PYG)Guyanese dollar (GYD)Uruguayan peso (UYU)Lesotho loti (LSL)Comorian franc (KMF)
Population6,900,000810,0003,400,0002,300,000850,000
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, with ten regions run by elected Regional Democratic Councils and a Local Government Commission. Indigenous Amerindian communities hold titled village lands under the Amerindian Act 2006 with village councils exercising defined local authority.Unitary. Nineteen departments have elected intendentes and juntas with administrative and local taxing competence, and municipalities were added in 2010, but all legislative power belongs to the General Assembly.Unitary with ten districts, and a recognised hierarchy of chiefs exercising customary functions over land allocation and local dispute resolution. The Senate includes the twenty-two principal chiefs ex officio.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 are read three times in the National Assembly, considered in committee, and assented to by the President, who may withhold assent and return a bill once. Money bills are the executive's initiative. Ordinary amendment of the Constitution needs two-thirds of all elected members; deeply entrenched articles additionally require approval at a referendum.Bills pass both chambers; disagreement is resolved by the General Assembly sitting jointly. The executive may veto, overcome by three-fifths of the joint assembly. Distinctively, 25% of registered voters can force a referendum to repeal a statute within one year of promulgation, and 10% can initiate a constitutional plebiscite.Bills pass three readings in the National Assembly, go to the Senate for review, and receive royal assent. The Senate can delay but not indefinitely block ordinary bills. Amendments to entrenched constitutional provisions require a two-thirds majority and, for the most protected clauses, a referendum.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: an attorney-at-law both advises and appears. Qualification is normally an LLB from the University of Guyana followed by the Legal Education Certificate from a Council of Legal Education school, then admission by the High Court. The Guyana Bar Association represents practitioners while discipline rests with the courts.A degree from the Universidad de la Repรบblica or an accredited private faculty confers the title of abogado, with registration by the Supreme Court. Membership of the Colegio de Abogados del Uruguay is voluntary; the Supreme Court exercises discipline. Escribanos pรบblicos are a separate profession with exclusive competence over conveyancing.A split profession in form โ€” advocates and attorneys are separately admitted under the Legal Practitioners Act โ€” though in practice many practitioners hold both admissions; the Law Society of Lesotho regulates the attorneys' branch.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.