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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
AttributeSaudi ArabiaReviewedBruneiReviewed
Legal familyIslamic lawMixed common law and Islamic law
System of governmentUnitary Islamic absolute monarchyAbsolute monarchy
ConstitutionBasic Law of GovernanceConstitution of Brunei Darussalam
In force since19921959
CapitalRiyadhBandar Seri Begawan
Official languagesArabicMalay, English
CurrencySaudi riyal (SAR)Brunei dollar (BND)
Population36,900,000450,000
Division of powersUnitary. Thirteen provinces headed by governors drawn from the royal family and appointed by the King, each with an appointed provincial council. No legislative competence exists below the national level.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 madeThere is no legislature with power to enact law. Proposals originate in ministries or the Shura Council, are considered by the Council of Ministers, and take effect as royal decrees signed by the King and published in Umm al-Qura. The Shura Council may study and recommend but its resolutions require royal approval, and the King may legislate without consulting it.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 professionAdvocates are licensed under the Code of Law Practice and must be Saudi nationals to appear in court, though licensed foreign firms may advise and now associate more freely following the 2024 opening. Judges are appointed from graduates of Sharia faculties by the Supreme Judicial Council and the King. Notarisation is a judicial function performed by notaries within the Ministry of Justice, and most commercial documentation must be executed in Arabic to be enforceable onshore.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.