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Comparison of selected legal systems
AttributeParaguayReviewedMaldivesReviewedChadIndexedAustriaReviewedFijiReviewed
Legal familyCivil lawMixed Islamic and common lawMixed (French civil law, customary and Islamic law)Civil lawCommon law with customary law
System of governmentUnitary presidential republicPresidential republicUnitary presidential republicFederal parliamentary republicUnitary parliamentary republic
ConstitutionConstitution of the Republic of ParaguayConstitution of the Republic of MaldivesConstitution of the Republic of ChadBundes-Verfassungsgesetz (B-VG)Constitution of the Republic of Fiji
In force since19922008202319202013
CapitalAsunciรณnMalรฉN'DjamenaViennaSuva
Official languagesSpanish, GuaranรญDhivehiFrench, ArabicGermanEnglish, Fijian, Fiji Hindi
CurrencyParaguayan guaranรญ (PYG)Maldivian rufiyaa (MVR)Central African CFA franc (XAF)Euro (EUR)Fijian dollar (FJD)
Population6,900,000521,00018,300,0009,100,000930,000
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 layer under the Decentralisation Act 2010: 21 atolls with elected atoll councils, plus island and city councils. Councils have limited revenue-raising and service delivery functions; the geography of roughly 190 inhabited islands makes administrative decentralisation a practical necessity rather than a constitutional division of sovereignty.Presidential system with a Prime Minister, a bicameral Parliament of National Assembly and Senate under the 2023 text, and a judiciary headed by the Supreme Court.Nine Lรคnder hold their own constitutions, parliaments and governments, but the federation retains far more legislative power than in Germany or Switzerland; much Lรคnder activity is administering federal law (mittelbare Bundesverwaltung). Three separate high courts sit at the apex, for constitutional, administrative and ordinary matters respectively.Unitary and deliberately centralised. Section 1 declares Fiji a sovereign state whose Parliament legislates for the whole country; there are no provinces with legislative power. The 14 provincial councils and the iTaukei Affairs Board administer indigenous affairs under the iTaukei Affairs Act. Rotuma has a distinct status under the Rotuma Act.
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 the Majlis by simple majority and go to the President, who may assent or return the bill once; a second passage requires assent. The Attorney General advises on constitutionality, and the Supreme Court may rule on it after enactment. Constitutional amendments need a two-thirds majority, and amendments to specified provisions also require a public referendum.Bills are examined in committee and plenary and passed by the legislature, then promulgated by the President. The Constitutional Council may be seised before promulgation.Bills originate with the government, members of the Nationalrat, the Bundesrat or a popular initiative, and pass three readings in the Nationalrat. The Bundesrat may object but can normally be overridden. The Federal President authenticates the law, the Chancellor countersigns, and it is published in the Bundesgesetzblatt.Bills are introduced in the unicameral Parliament, referred to a standing committee, and pass through second reading, committee and third reading before assent by the President. There is no upper house. A constitutional amendment requires the support of three-quarters of all members of Parliament and then approval by three-quarters of registered voters at a referendum, a threshold that has never been met.
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.Lawyers are licensed and regulated by the Maldives Bar Council, established under the Legal Profession Act 2019 โ€” before which licensing sat with the Attorney General's office and then the Department of Judicial Administration. A recognised law degree, the Bar examination and a period of training are required, and licences are tiered by the level of court in which the lawyer may appear.Avocats admitted through the Ordre des avocats du Tchad; the profession is concentrated in N'Djamena.A Rechtsanwalt qualifies through a law degree, five years of practical training including at least three in a law firm and some months at court, and the bar examination. Admission is via the regional bar chambers under the umbrella of the ร–sterreichischer Rechtsanwaltskammertag. Notaries are a separate profession with appointments limited in number.A fused profession under the Legal Practitioners Act 2009: practitioners are admitted by the Chief Justice as barristers and solicitors. Most qualify through the University of the South Pacific law degree followed by the Professional Diploma in Legal Practice. Admission and discipline are handled by the Chief Registrar and the Independent Legal Services Commission rather than by the Fiji Law Society, which is a voluntary professional body.

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.