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Comparison of selected legal systems
AttributeParaguayReviewedLibyaIndexedComorosReviewedMoroccoReviewed
Legal familyCivil lawCivil law with Islamic law as a sourceMixed French civil law and Islamic lawCivil law with Islamic law in personal status
System of governmentUnitary presidential republicProvisional government with contested authorityFederal presidential republicConstitutional monarchy
ConstitutionConstitution of the Republic of ParaguayConstitutional Declaration (interim)Constitution of the Union of the ComorosConstitution of the Kingdom of Morocco
In force since1992201120012011
CapitalAsunciรณnTripoliMoroniRabat
Official languagesSpanish, GuaranรญArabicComorian, Arabic, FrenchArabic, Tamazight
CurrencyParaguayan guaranรญ (PYG)Libyan dinar (LYD)Comorian franc (KMF)Moroccan dirham (MAD)
Population6,900,0006,900,000850,00037,500,000
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.Nominally unitary with governorates and municipalities. In practice authority is divided between competing administrations and local armed actors, and municipal councils have in many places become the most functional layer of government.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 but substantially regionalised since 2015, with twelve regions holding directly elected councils and their own budgets under the advanced regionalisation programme. Regions have executive competences in development planning and transport; they do not legislate.
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.There is no single functioning legislative process. The House of Representatives passes laws that the High Council of State contests, and the rival administrations issue decrees within their areas of control. Whether a given instrument is law therefore depends on which authority is recognised, which is exactly why this profile is marked as requiring research rather than described as settled.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 may be introduced by the head of government or by members of either chamber. They pass through committee and plenary in both houses, with the House of Representatives having the final word where the chambers disagree. Organic laws must be referred to the Constitutional Court before promulgation. The King promulgates statutes by dahir within thirty days, and may ask parliament to reconsider a bill or submit it to 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.Advocates are admitted through the Libyan Bar Association, and the profession has continued to function, including in human-rights litigation, despite serious risks to practitioners. Judicial appointments run through the Supreme Judicial Council. Reliable current information on admission requirements and numbers is limited, which is reflected in the verification status of this entry.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.Avocats are admitted to one of the regional bars and organised nationally through the Association des Barreaux du Maroc; practice before the Court of Cassation requires additional seniority. Notaries and adouls coexist โ€” the notaire handles conveyancing and company documents in the French tradition, while the adoul draws up marriage and inheritance instruments under Islamic law. Judges are career appointments trained at the Institut Supรฉrieur de la Magistrature.

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.