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Comparison

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Comparison of selected legal systems
AttributeParaguayReviewedIranReviewedComorosReviewedNamibiaReviewedPeruReviewed
Legal familyCivil lawIslamic law with civil law codificationMixed French civil law and Islamic lawMixed Roman-Dutch and English common lawCivil law
System of governmentUnitary presidential republicIslamic republicFederal presidential republicSemi-presidential republicUnitary semi-presidential republic
ConstitutionConstitution of the Republic of ParaguayConstitution of the Islamic Republic of IranConstitution of the Union of the ComorosConstitution of the Republic of NamibiaPolitical Constitution of Peru
In force since19921979200119901993
CapitalAsunciรณnTehranMoroniWindhoekLima
Official languagesSpanish, GuaranรญPersianComorian, Arabic, FrenchEnglishSpanish, Quechua, Aymara
CurrencyParaguayan guaranรญ (PYG)Rial (IRR)Comorian franc (KMF)Namibian dollar (NAD)Peruvian sol (PEN)
Population6,900,00089,000,000850,0002,600,00034,000,000
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 31 provinces headed by governors-general appointed by the Interior Ministry, alongside elected city and village councils created by the Constitution and operating since 1999 with limited competences.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 14 administrative regions and elected regional councils, which also constitute the National Council, the upper chamber. Traditional authorities exercise recognised functions over communal land and customary law.Unitary and decentralised, with twenty-five regional governments and the Lima Metropolitan Municipality holding elected councils and administrative competence. Peasant and native communities exercise jurisdiction within their territory under Article 149 in coordination with the justices of the peace.
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.A bill is introduced by the Government or by at least fifteen deputies, passes the Majlis, and goes to the Guardian Council, which has ten days, extendable, to find it consistent with Islam and the Constitution. If the Council objects, the bill returns for amendment; persistent disagreement goes to the Expediency Discernment Council, whose decision is final. Only then does the President sign and publish.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.Bills pass the National Assembly through three readings, then go to the National Council for review. The Council may confirm, propose amendments, or object; the Assembly can override an objection by a two-thirds majority. The President then assents, and constitutional amendments require two-thirds of both chambers and may never diminish the rights chapter.Bills come from Congress, the executive, regional governments or citizens. A single chamber debates in committee and plenary; a second vote is required unless exempted. The President may observe a bill, and Congress insists by absolute majority. Constitutional amendment needs an absolute majority in two successive ordinary legislatures, or a two-thirds vote plus 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.Two parallel routes to practice, which is unusual and consequential: attorneys licensed by the Iranian Bar Association (Kanoon-e Vokala), a self-governing body dating to 1953, and attorneys licensed under Article 187 of the Third Development Plan directly by the judiciary. The two groups have contested each other's standing for two decades. Notaries operate licensed offices under the registration organisation, and their authentication is required for property transfers, marriage contracts and powers of attorney.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 under the Legal Practitioners Act: a single class of legal practitioner is admitted after a law degree and the Justice Training Centre's postgraduate course, and the Law Society of Namibia regulates practice.A law degree followed by a bachiller and tรญtulo de abogado, then compulsory registration with one of the departmental colegios de abogados, which hold disciplinary power. Registration in one college permits practice nationwide. Notaries are a separate profession appointed by competitive examination.

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.