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Comparison

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Because every portal follows the same fifteen-section outline, the comparison is genuinely like-for-like rather than a collage of whatever each government happens to publish.

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Comparison of selected legal systems
AttributeParaguayReviewedVanuatuReviewedLesothoReviewedMoroccoReviewed
Legal familyCivil lawMixed common, civil and customary lawMixed Roman-Dutch and English common lawCivil law with Islamic law in personal status
System of governmentUnitary presidential republicUnitary parliamentary republicParliamentary constitutional monarchyConstitutional monarchy
ConstitutionConstitution of the Republic of ParaguayConstitution of the Republic of VanuatuConstitution of LesothoConstitution of the Kingdom of Morocco
In force since1992198019932011
CapitalAsunciรณnPort VilaMaseruRabat
Official languagesSpanish, GuaranรญBislama, English, FrenchSesotho, EnglishArabic, Tamazight
CurrencyParaguayan guaranรญ (PYG)Vanuatu vatu (VUV)Lesotho loti (LSL)Moroccan dirham (MAD)
Population6,900,000330,0002,300,00037,500,000
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 decentralised administration. Six provinces โ€” Malampa, Penama, Sanma, Shefa, Tafea and Torba โ€” have councils under the Decentralisation Act with delegated functions. Custom land management is decentralised much further, to area-level Custom Land Tribunals and nakamal-based decision-making under the Custom Land Management Act 2013.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 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.
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 single chamber and assented to by the President, who may refer a bill to the Supreme Court if he considers it inconsistent with the Constitution. Ordinary bills need a simple majority of members present, with a quorum of two-thirds. Constitutional amendments require a two-thirds majority of all members; if the amendment touches the status of Bislama, English or French, land, or the republican form of the state, it must also be approved at a national referendum.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 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.
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 regulated by the Legal Practitioners Act: practitioners are admitted by the Chief Justice and licensed by the Law Council. The University of the South Pacific's law school is in Port Vila, so many Pacific lawyers train in Vanuatu. Practitioners may need to work in Bislama, English or French depending on the client and the court file, and the Public Solicitor is a constitutional office rather than a discretionary aid scheme.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.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 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.