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Comparison of selected legal systems
AttributeParaguayReviewedSaudi ArabiaReviewedMoroccoReviewedComorosReviewed
Legal familyCivil lawIslamic lawCivil law with Islamic law in personal statusMixed French civil law and Islamic law
System of governmentUnitary presidential republicUnitary Islamic absolute monarchyConstitutional monarchyFederal presidential republic
ConstitutionConstitution of the Republic of ParaguayBasic Law of GovernanceConstitution of the Kingdom of MoroccoConstitution of the Union of the Comoros
In force since1992199220112001
CapitalAsunciรณnRiyadhRabatMoroni
Official languagesSpanish, GuaranรญArabicArabic, TamazightComorian, Arabic, French
CurrencyParaguayan guaranรญ (PYG)Saudi riyal (SAR)Moroccan dirham (MAD)Comorian franc (KMF)
Population6,900,00036,900,00037,500,000850,000
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. Thirteen provinces headed by governors drawn from the royal family and appointed by the King, each with an appointed provincial council. No legislative competence exists below the national level.Unitary but substantially regionalised since 2015, with twelve regions holding directly elected councils and their own budgets under the advanced regionalisation programme. Regions have executive competences in development planning and transport; they do not legislate.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.There is no legislature with power to enact law. Proposals originate in ministries or the Shura Council, are considered by the Council of Ministers, and take effect as royal decrees signed by the King and published in Umm al-Qura. The Shura Council may study and recommend but its resolutions require royal approval, and the King may legislate without consulting it.Bills may be introduced by the head of government or by members of either chamber. They pass through committee and plenary in both houses, with the House of Representatives having the final word where the chambers disagree. Organic laws must be referred to the Constitutional Court before promulgation. The King promulgates statutes by dahir within thirty days, and may ask parliament to reconsider a bill or submit it to referendum.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 are licensed under the Code of Law Practice and must be Saudi nationals to appear in court, though licensed foreign firms may advise and now associate more freely following the 2024 opening. Judges are appointed from graduates of Sharia faculties by the Supreme Judicial Council and the King. Notarisation is a judicial function performed by notaries within the Ministry of Justice, and most commercial documentation must be executed in Arabic to be enforceable onshore.Avocats are admitted to one of the regional bars and organised nationally through the Association des Barreaux du Maroc; practice before the Court of Cassation requires additional seniority. Notaries and adouls coexist โ€” the notaire handles conveyancing and company documents in the French tradition, while the adoul draws up marriage and inheritance instruments under Islamic law. Judges are career appointments trained at the Institut Supรฉrieur de la Magistrature.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.