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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
AttributeParaguayReviewedMadagascarReviewedUruguayReviewedKenyaReviewed
Legal familyCivil lawFrench civil law with customary lawCivil lawMixed (common law, customary law, Islamic law)
System of governmentUnitary presidential republicSemi-presidential republicUnitary presidential republicUnitary presidential republic with devolved counties
ConstitutionConstitution of the Republic of ParaguayConstitution of the Fourth RepublicConstitution of the Oriental Republic of UruguayConstitution of Kenya
In force since1992201019672010
CapitalAsunciรณnAntananarivoMontevideoNairobi
Official languagesSpanish, GuaranรญMalagasy, FrenchSpanishEnglish, Swahili
CurrencyParaguayan guaranรญ (PYG)Malagasy ariary (MGA)Uruguayan peso (UYU)Kenyan Shilling (KES)
Population6,900,00030,300,0003,400,00055,100,000
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 a decentralised structure of 23 regions and communes. Successive constitutions have promised fuller decentralisation, including provincial autonomy, which has not been implemented.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.Presidential system with no Prime Minister, a bicameral Parliament of National Assembly and Senate, 47 county governments with their own assemblies and executives, and an independent judiciary supervised by the Judicial Service Commission.
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 originate with the government or members of either chamber, are examined in committee, and must pass both the National Assembly and the Senate; the Assembly prevails on disagreement. The Haute Cour Constitutionnelle may review a law before promulgation, and organic laws must be referred to it as a matter of course.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 are read three times with committee scrutiny and public participation, which the courts treat as a justiciable requirement. Bills concerning counties must pass both chambers. The President assents or refers the bill back with reservations, which Parliament may override by two-thirds.
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.Avocats admitted to the Ordre des avocats de Madagascar after a law degree and professional training, alongside notaires for authenticated instruments and huissiers for service and enforcement โ€” the standard French division of functions.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.Fused: an LLB, the Kenya School of Law advocates training programme, and admission by the Chief Justice produce an advocate of the High Court. The Law Society of Kenya is the professional body; Senior Counsel is the senior rank.

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.