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Comparison of selected legal systems
AttributeParaguayReviewedTongaReviewedComorosReviewedBruneiReviewed
Legal familyCivil lawCommon law with customary lawMixed French civil law and Islamic lawMixed common law and Islamic law
System of governmentUnitary presidential republicConstitutional monarchyFederal presidential republicAbsolute monarchy
ConstitutionConstitution of the Republic of ParaguayAct of Constitution of TongaConstitution of the Union of the ComorosConstitution of Brunei Darussalam
In force since1992187520011959
CapitalAsunciรณnNuku'alofaMoroniBandar Seri Begawan
Official languagesSpanish, GuaranรญTongan, EnglishComorian, Arabic, FrenchMalay, English
CurrencyParaguayan guaranรญ (PYG)Tongan paสปanga (TOP)Comorian franc (KMF)Brunei dollar (BND)
Population6,900,000105,000850,000450,000
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. The Legislative Assembly legislates for the whole kingdom, and the island divisions of Tongatapu, Vava'u, Ha'apai, 'Eua and the Niuas are administrative districts headed by governors. Below that, town and district officers are elected under the Fakafekau'aki and District and Town Officers Act.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 four districts administered by district officers reporting to the Ministry of Home Affairs. No federal or devolved tier; village and mukim headmen have recognised consultative functions.
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 three readings in the Legislative Assembly and require the King's assent, which is a real rather than purely formal step. Ordinary bills need a simple majority. Amendments to the Constitution require a majority in the Assembly at three separate readings and the consent of the King and Privy Council, and clause 79 forbids any amendment affecting the law of liberty, the succession to the throne or the titles and hereditary estates of the nobles.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.In form, bills are introduced in the Legislative Council and assented to by the Sultan. In practice the significant instruments are Orders made by the Sultan under the emergency proclamation, which take effect on publication in the Government Gazette without Council passage. The Syariah Penal Code Order 2013 was enacted this way.
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.Law practitioners are admitted by the Chief Justice and licensed under the Law Practitioners Act, with the Tonga Law Society as the professional body. Most qualify overseas or at the University of the South Pacific. A practitioner working on land must know the Land Act's allotment system rather than general property law, because the constitutional bar on selling land means conveyancing in the ordinary sense does not exist.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.Advocates and solicitors are admitted by the High Court under the Legal Profession Act, generally after qualifying in England, Malaysia, Singapore or Australia and completing local requirements. The profession is small โ€” a few hundred practitioners โ€” and foreign counsel may be admitted ad hoc for particular cases. Syariah practice is a separate track: Syariah lawyers are certified under the Syariah Courts Act and appear only in the Syariah hierarchy, so a matter that crosses both systems needs two sets of representation.

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.