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Comparison of selected legal systems
AttributeParaguayReviewedSeychellesReviewedDenmarkReviewedMyanmarReviewedEritreaIndexed
Legal familyCivil lawMixed French civil law and English common lawCivil law (Nordic)Common law with codified statutesCivil law with customary law
System of governmentUnitary presidential republicPresidential republicConstitutional monarchyMilitary administration; constitutional order suspendedSingle-party state
ConstitutionConstitution of the Republic of ParaguayConstitution of the Republic of SeychellesConstitutional Act of Denmark (Grundloven)Constitution of the Republic of the Union of MyanmarConstitution of Eritrea (ratified 1997, never implemented)
In force since19921993195320081997
CapitalAsunciรณnVictoriaCopenhagenNaypyidawAsmara
Official languagesSpanish, GuaranรญSeychellois Creole, English, FrenchDanishBurmeseTigrinya, Arabic, English
CurrencyParaguayan guaranรญ (PYG)Seychellois rupee (SCR)Danish krone (DKK)Kyat (MMK)Eritrean nakfa (ERN)
Population6,900,000130,0005,900,00054,500,0003,700,000
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 27 administrative districts. The outer islands are administered centrally, and the Seychelles' extensive exclusive economic zone is a significant focus of regulation.Parliamentary government in which the cabinet is drawn from and answerable to the Folketing, with an independent unified judiciary.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, with six regions and sub-regional administrations whose administrators are centrally appointed. There is no elected regional tier and no legislative devolution.
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 National Assembly with committee scrutiny and receive presidential assent; the President may refer a bill to the Constitutional Court on a question of constitutionality before assent. Constitutional amendments require a two-thirds majority, and amendments to certain protected provisions additionally require a referendum.Bills pass three readings in the Folketing and receive royal assent. A minority of members can require certain bills to be put to a referendum.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.There is no functioning parliamentary process. Law is made by proclamation issued through the executive and published in the Gazette of Eritrean Laws. Because the National Assembly has not sat for more than two decades, the ordinary description of a legislative procedure would be inapplicable.
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 of attorneys-at-law admitted by the Supreme Court after a recognised law qualification and pupillage, with the Bar Association of Seychelles representing practitioners.A single advokat profession admitted after a law degree, practical training and a bar course; judges are appointed from experienced lawyers.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.The profession is very small. Advocates are licensed by the Ministry of Justice, there is no independent bar association, and legal education runs through a limited number of state institutions following the closure of the University of Asmara as a degree-granting body in 2006. Representation is not permitted before the Special Court. Reliable current figures are not available.

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.