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Comparison of selected legal systems
AttributeParaguayReviewedSamoaReviewedCanadaReviewedGrenadaReviewedUruguayReviewed
Legal familyCivil lawCommon law with customary lawBijural: common law and Quรฉbec civil lawCommon lawCivil law
System of governmentUnitary presidential republicUnitary parliamentary republicFederal parliamentary constitutional monarchyConstitutional monarchyUnitary presidential republic
ConstitutionConstitution of the Republic of ParaguayConstitution of the Independent State of SamoaConstitution Acts, 1867 and 1982The Grenada ConstitutionConstitution of the Oriental Republic of Uruguay
In force since19921962198219731967
CapitalAsunciรณnApiaOttawaSaint George'sMontevideo
Official languagesSpanish, GuaranรญSamoan, EnglishEnglish, FrenchEnglishSpanish
CurrencyParaguayan guaranรญ (PYG)Samoan tฤlฤ (WST)Canadian Dollar (CAD)East Caribbean dollar (XCD)Uruguayan peso (UYU)
Population6,900,000220,00041,200,000126,0003,400,000
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. Parliament legislates for the whole country. Below it, about 250 villages govern themselves through the village fono (council of matai) under the Village Fono Act 1990, which gives customary village authority statutory recognition โ€” a genuine layer of local government rather than a delegation of central power.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.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.
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 are read three times in the Legislative Assembly, usually with parliamentary committee scrutiny, and are then assented to by the O le Ao o le Malo. Ordinary bills need a simple majority. Constitutional amendments require a two-thirds majority of all members at the third reading, and any amendment affecting customary land or matai titles is politically entrenched by the strength of the fa'a Samoa consensus even where the two-thirds threshold is met.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.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.
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.A fused profession under the Lawyers and Legal Practice Act 2014: lawyers are admitted by the Supreme Court and must hold a practising certificate from the Samoa Law Society. Most qualify at the University of the South Pacific or in New Zealand. Practice before the Land and Titles Court is different in character from ordinary litigation, because the issues are matai genealogy and customary entitlement rather than statutory or common-law rights.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 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.

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.