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Comparison of selected legal systems
AttributeParaguayReviewedYemenReviewedMoroccoReviewedComorosReviewed
Legal familyCivil lawMixed (Islamic law and civil law)Civil law with Islamic law in personal statusMixed French civil law and Islamic law
System of governmentUnitary presidential republicRepublic with contested authorityConstitutional monarchyFederal presidential republic
ConstitutionConstitution of the Republic of ParaguayConstitution of the Republic of YemenConstitution of the Kingdom of MoroccoConstitution of the Union of the Comoros
In force since1992199120112001
CapitalAsunciรณnSana'a (constitutional); Aden (interim seat of government)RabatMoroni
Official languagesSpanish, GuaranรญArabicArabic, TamazightComorian, Arabic, French
CurrencyParaguayan guaranรญ (PYG)Yemeni rial (YER)Moroccan dirham (MAD)Comorian franc (KMF)
Population6,900,00034,400,00037,500,000850,000
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.Nominally unitary with twenty-two governorates and appointed governors, and a 2000 local authority law providing for elected local councils. In practice territorial control is divided between rival authorities, and the 2015 draft federal constitution proposing six regions was never adopted.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.Under the constitution, bills are passed by the House of Representatives and ratified by the head of state, with publication in the Official Gazette. Since 2014 this process has not operated normally: the recognised government legislates largely by decree from Aden, and the Houthi authorities issue their own instruments in the areas they control. Determining the applicable rule in a given place and period is a factual question, not merely a legal one.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 Advocacy Law and organised in the Yemeni Bar Association, which has continued to operate and to make representations about judicial independence throughout the conflict. Judges are trained at the High Judicial Institute and appointed by the Supreme Judicial Council, but appointments made by rival authorities since 2014 are not mutually recognised. Legal aid is minimal and provided mainly by non-governmental organisations.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.