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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
AttributeSenegalReviewedKuwaitReviewedNauruReviewed
Legal familyCivil law (French tradition)Mixed (civil law and Islamic law)Common law with customary law
System of governmentUnitary presidential republicUnitary constitutional monarchyParliamentary republic
ConstitutionConstitution of the Republic of SenegalConstitution of the State of KuwaitConstitution of Nauru
In force since200119621968
CapitalDakarKuwait CityYaren (seat of government)
Official languagesFrench, Wolof, Pulaar, SererArabicNauruan, English
CurrencyWest African CFA franc (XOF)Kuwaiti dinar (KWD)Australian dollar (AUD)
Population17,700,0004,300,00012,500
Division of powersA strong executive presidency with a Prime Minister and Council of Ministers, a unicameral National Assembly, and a judiciary in which the Conseil constitutionnel, Cour suprรชme and Cour des comptes occupy separate apexes.Unitary. Six governorates administered by appointed governors, with no legislative competence.Unitary and highly centralised โ€” Nauru has no second tier of general government. The Nauru Island Council was abolished in 1999, so the state deals directly with citizens, though the 14 districts remain the basis for parliamentary constituencies and the twelve tribes retain social significance in land and title questions.
How law is madeBills originate with the government or deputies, are examined in committee and voted in plenary. The President promulgates within the constitutional period or refers the text to the Conseil constitutionnel.Under the constitution as designed, bills passed by the National Assembly required Emiri sanction, and the Emir could return a bill for reconsideration which the Assembly could override by a two-thirds majority. With the Assembly dissolved and the relevant articles suspended since May 2024, legislation is made by Emiri decree on the proposal of the Council of Ministers and published in the Official Gazette (Kuwait Al-Youm).Bills receive three readings in the 19-member chamber and are assented to by the President. Ordinary legislation needs a simple majority, but the entrenched provisions of Part XI require a two-thirds majority and, for the most protected articles, approval at a referendum โ€” the barrier that defeated the 2010 reform proposals.
Legal professionAvocats are admitted to the Ordre des avocats du Sรฉnรฉgal after a law degree, the CFPA professional course and a traineeship. Notaires and huissiers are separate regulated professions.Advocacy is reserved to Kuwaiti nationals enrolled with the Ministry of Justice and the Kuwait Bar Association, with foreign lawyers acting as consultants and unable to appear; pleadings are in Arabic. Judges are appointed by the Supreme Judicial Council, and a significant proportion of the bench has historically been seconded from other Arab states. Notarial authentication at the Ministry of Justice is required for powers of attorney, property transfers and company formation documents.A very small fused profession admitted by the Supreme Court under the Legal Practitioners Act 1973, supplemented by pleaders โ€” non-lawyers licensed to appear in the District Court and before the Lands Committee, a practical necessity given the number of resident lawyers. Judicial officers are frequently appointed from Australia, New Zealand or elsewhere in the Pacific.

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.