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Comparison of selected legal systems
AttributeParaguayReviewedSudanIndexedComorosReviewedLesothoReviewedGrenadaReviewed
Legal familyCivil lawMixed Islamic and common lawMixed French civil law and Islamic lawMixed Roman-Dutch and English common lawCommon law
System of governmentUnitary presidential republicMilitary government following the 2021 coup and 2023 warFederal presidential republicParliamentary constitutional monarchyConstitutional monarchy
ConstitutionConstitution of the Republic of ParaguayDraft Constitutional Charter for the Transitional PeriodConstitution of the Union of the ComorosConstitution of LesothoThe Grenada Constitution
In force since19922019200119931973
CapitalAsunciรณnKhartoumMoroniMaseruSaint George's
Official languagesSpanish, GuaranรญArabic, EnglishComorian, Arabic, FrenchSesotho, EnglishEnglish
CurrencyParaguayan guaranรญ (PYG)Sudanese pound (SDG)Comorian franc (KMF)Lesotho loti (LSL)East Caribbean dollar (XCD)
Population6,900,00048,100,000850,0002,300,000126,000
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.Formally federal, with states headed by governors. The Juba Peace Agreement of 2020 contemplated regional arrangements for Darfur and the Two Areas. Effective authority is currently divided between the belligerents and varies by locality.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.Unitary with ten districts, and a recognised hierarchy of chiefs exercising customary functions over land allocation and local dispute resolution. The Senate includes the twenty-two principal chiefs ex officio.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.The Charter assigned legislation to a joint sitting of the Sovereignty Council and the cabinet pending the formation of a legislative council, which never fully happened. Since 2021 instruments have been issued by decree. There is no verifiable ordinary legislative process at present, which is why this profile is marked as requiring research.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.Bills pass three readings in the National Assembly, go to the Senate for review, and receive royal assent. The Senate can delay but not indefinitely block ordinary bills. Amendments to entrenched constitutional provisions require a two-thirds majority and, for the most protected clauses, a referendum.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.Advocates are admitted through the Sudanese Bar Association, and the profession โ€” particularly the Sudanese Professionals Association and the emergency lawyers' groups โ€” was central to the 2019 protest movement and to documenting subsequent abuses. Judges are career appointments through the Judicial Service Commission. Current admission practice and numbers cannot be reliably confirmed.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 split profession in form โ€” advocates and attorneys are separately admitted under the Legal Practitioners Act โ€” though in practice many practitioners hold both admissions; the Law Society of Lesotho regulates the attorneys' branch.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.