Comparison

Read two legal systems against each other

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
Attribute	SamoaReviewed	ComorosReviewed	MalaysiaReviewed
Legal family	Common law with customary law	Mixed French civil law and Islamic law	Mixed common law and Islamic law
System of government	Unitary parliamentary republic	Federal presidential republic	Federal constitutional monarchy
Constitution	Constitution of the Independent State of Samoa	Constitution of the Union of the Comoros	Federal Constitution of Malaysia
In force since	1962	2001	1957
Capital	Apia	Moroni	Kuala Lumpur
Official languages	Samoan, English	Comorian, Arabic, French	Malay, English
Currency	Samoan tālā (WST)	Comorian franc (KMF)	Malaysian ringgit (MYR)
Population	220,000	850,000	34,100,000
Division of powers	Unitary. Parliament legislates for the whole country. Below it, about 250 villages govern themselves through the village fono (council of matai) under the Village Fono Act 1990, which gives customary village authority statutory recognition — a genuine layer of local government rather than a delegation of central power.	Federal. Grande Comore, Anjouan and Mohéli each have a governor and their own assembly with substantial autonomy over local administration, while the Union handles defence, currency, foreign affairs and nationality.	Federal, with 13 states and three federal territories. The Ninth Schedule sets out Federal, State and Concurrent Lists: land, Islamic law, Malay custom and local government are state matters, while trade, finance, defence and civil and criminal law are federal. Sabah and Sarawak hold additional competences — immigration, native customary land, and their own High Court — reflecting the terms on which they joined.
How law is made	Bills are read three times in the Legislative Assembly, usually with parliamentary committee scrutiny, and are then assented to by the O le Ao o le Malo. Ordinary bills need a simple majority. Constitutional amendments require a two-thirds majority of all members at the third reading, and any amendment affecting customary land or matai titles is politically entrenched by the strength of the fa'a Samoa consensus even where the two-thirds threshold is met.	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 both houses; the Dewan Negara can delay but not block, and money bills originate in the Dewan Rakyat. Royal assent is required and, since a 1994 amendment, is deemed given after 30 days if withheld. Amendments affecting the rulers, the special position of the Malays, citizenship or the position of Sabah and Sarawak require additional consents beyond the two-thirds majority.
Legal profession	A fused profession under the Lawyers and Legal Practice Act 2014: lawyers are admitted by the Supreme Court and must hold a practising certificate from the Samoa Law Society. Most qualify at the University of the South Pacific or in New Zealand. Practice before the Land and Titles Court is different in character from ordinary litigation, because the issues are matai genealogy and customary entitlement rather than statutory or common-law rights.	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 fused profession of advocates and solicitors, but regulated separately by territory: the Malaysian Bar under the Legal Profession Act 1976 for Peninsular Malaysia, the Sabah Law Society, and the Advocates Association of Sarawak. Admission requires a recognised law degree or the Certificate in Legal Practice, pupillage of nine months, and admission by the High Court. Syariah practitioners are separately admitted by state Syariah authorities and require Syariah law qualifications.

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 — the constitutional detail behind a one-line summary is often the part that governs the outcome.