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Comparison of selected legal systems
AttributeParaguayReviewedMyanmarReviewedNauruReviewedComorosReviewed
Legal familyCivil lawCommon law with codified statutesCommon law with customary lawMixed French civil law and Islamic law
System of governmentUnitary presidential republicMilitary administration; constitutional order suspendedParliamentary republicFederal presidential republic
ConstitutionConstitution of the Republic of ParaguayConstitution of the Republic of the Union of MyanmarConstitution of NauruConstitution of the Union of the Comoros
In force since1992200819682001
CapitalAsunciรณnNaypyidawYaren (seat of government)Moroni
Official languagesSpanish, GuaranรญBurmeseNauruan, EnglishComorian, Arabic, French
CurrencyParaguayan guaranรญ (PYG)Kyat (MMK)Australian dollar (AUD)Comorian franc (KMF)
Population6,900,00054,500,00012,500850,000
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 a union of seven regions, seven states, one union territory and six self-administered zones and divisions, each with its own legislature under the 2008 Constitution. In practice the region and state legislatures are suspended or subordinated to the military administration, and chief ministers are appointed centrally.Unitary and highly centralised โ€” Nauru has no second tier of general government. The Nauru Island Council was abolished in 1999, so the state deals directly with citizens, though the 14 districts remain the basis for parliamentary constituencies and the twelve tribes retain social significance in land and title questions.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.
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.Under the 2008 Constitution, bills passed both chambers and went to the President, with disagreements resolved in joint sitting. Since February 2021 legislation is made by the State Administration Council as law or order, published in the Gazette without legislative passage, and a series of such instruments has amended the Penal Code, the electronic communications law and the criminal procedure code.Bills receive three readings in the 19-member chamber and are assented to by the President. Ordinary legislation needs a simple majority, but the entrenched provisions of Part XI require a two-thirds majority and, for the most protected articles, approval at a referendum โ€” the barrier that defeated the 2010 reform proposals.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.
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 and higher-grade pleaders are admitted under the Legal Practitioners Act 1879 and the Bar Council Act 1929, an inherited colonial framework, with the Supreme Court controlling the roll. Independent bar associations formed after 2011 but the Bar Council has long been closely supervised, and lawyers acting in political cases have themselves faced prosecution and disbarment since 2021. Legal aid exists under the Legal Aid Law 2016 but is thinly resourced.A very small fused profession admitted by the Supreme Court under the Legal Practitioners Act 1973, supplemented by pleaders โ€” non-lawyers licensed to appear in the District Court and before the Lands Committee, a practical necessity given the number of resident lawyers. Judicial officers are frequently appointed from Australia, New Zealand or elsewhere in the Pacific.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 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.