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Comparison of selected legal systems
AttributeParaguayReviewedMicronesiaReviewedComorosReviewedCanadaReviewedGrenadaReviewed
Legal familyCivil lawMixed common law with customary lawMixed French civil law and Islamic lawBijural: common law and Quรฉbec civil lawCommon law
System of governmentUnitary presidential republicFederal republic in free association with the United StatesFederal presidential republicFederal parliamentary constitutional monarchyConstitutional monarchy
ConstitutionConstitution of the Republic of ParaguayConstitution of the Federated States of MicronesiaConstitution of the Union of the ComorosConstitution Acts, 1867 and 1982The Grenada Constitution
In force since19921979200119821973
CapitalAsunciรณnPalikirMoroniOttawaSaint George's
Official languagesSpanish, GuaranรญEnglish, Chuukese, Pohnpeian, Yapese, KosraeanComorian, Arabic, FrenchEnglish, FrenchEnglish
CurrencyParaguayan guaranรญ (PYG)United States dollar (USD)Comorian franc (KMF)Canadian Dollar (CAD)East Caribbean dollar (XCD)
Population6,900,000115,000850,00041,200,000126,000
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.Genuine federalism. The national government holds foreign affairs, defence, immigration, currency and interstate commerce; everything else, including land tenure, is state or local. Each state has its own constitution and supreme court, and Yap's constitution creates Councils of Pilung and Tamol โ€” traditional leaders' councils with power to disapprove state legislation affecting tradition and custom.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.Sections 91 and 92 divide federal and provincial competence. Section 33 allows a legislature to override certain Charter rights for renewable five-year periods.Unitary. The state comprises Grenada, Carriacou and Petite Martinique; Carriacou and Petite Martinique have a Ministry and local administration but no separate legislature.
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 Congress and are signed by the President, who has a veto that Congress may override. Because the four at-large senators serve longer terms and are the pool from which the President is drawn, national politics is structured around balancing the states rather than around parties โ€” there are no formal political parties. Constitutional amendments may be proposed by Congress, by a convention, or by popular initiative, and require ratification by three-quarters of the voters in three of the four states.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.Three readings plus committee study in each chamber, then Royal Assent. Money bills must originate in the Commons.Bills pass three readings in both Houses and receive the Governor-General's assent. Constitutional amendments to entrenched provisions need a two-thirds majority in the House of Representatives and then approval by a referendum, a double lock that has defeated every reform package put to voters.
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.Admission is to the FSM Supreme Court, with rules that recognise foreign qualifications, so many practitioners trained in the United States. A distinctive feature is the trial counselor: a non-lawyer licensed to appear in certain courts after examination, which is how most representation is delivered outside the main centres. Practitioners must often hold admission both nationally and in the relevant state.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.Provincial law societies regulate admission: an accredited degree, articles, and bar admission courses. Quรฉbec has separate avocat and notaire professions.A fused profession of legal practitioners admitted by the High Court under the Legal Profession Act, after a law degree and the Legal Education Certificate. The Grenada Bar Association represents practitioners.

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.