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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
AttributeSamoaReviewedNamibiaReviewedIranReviewed
Legal familyCommon law with customary lawMixed Roman-Dutch and English common lawIslamic law with civil law codification
System of governmentUnitary parliamentary republicSemi-presidential republicIslamic republic
ConstitutionConstitution of the Independent State of SamoaConstitution of the Republic of NamibiaConstitution of the Islamic Republic of Iran
In force since196219901979
CapitalApiaWindhoekTehran
Official languagesSamoan, EnglishEnglishPersian
CurrencySamoan tālā (WST)Namibian dollar (NAD)Rial (IRR)
Population220,0002,600,00089,000,000
Division of powersUnitary. 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.Unitary with 14 administrative regions and elected regional councils, which also constitute the National Council, the upper chamber. Traditional authorities exercise recognised functions over communal land and customary law.Unitary, with 31 provinces headed by governors-general appointed by the Interior Ministry, alongside elected city and village councils created by the Constitution and operating since 1999 with limited competences.
How law is madeBills 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 pass the National Assembly through three readings, then go to the National Council for review. The Council may confirm, propose amendments, or object; the Assembly can override an objection by a two-thirds majority. The President then assents, and constitutional amendments require two-thirds of both chambers and may never diminish the rights chapter.A bill is introduced by the Government or by at least fifteen deputies, passes the Majlis, and goes to the Guardian Council, which has ten days, extendable, to find it consistent with Islam and the Constitution. If the Council objects, the bill returns for amendment; persistent disagreement goes to the Expediency Discernment Council, whose decision is final. Only then does the President sign and publish.
Legal professionA 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 fused profession under the Legal Practitioners Act: a single class of legal practitioner is admitted after a law degree and the Justice Training Centre's postgraduate course, and the Law Society of Namibia regulates practice.Two parallel routes to practice, which is unusual and consequential: attorneys licensed by the Iranian Bar Association (Kanoon-e Vokala), a self-governing body dating to 1953, and attorneys licensed under Article 187 of the Third Development Plan directly by the judiciary. The two groups have contested each other's standing for two decades. Notaries operate licensed offices under the registration organisation, and their authentication is required for property transfers, marriage contracts and powers of attorney.

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.