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.
Select up to six documented jurisdictions
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| Attribute | South AfricaReviewed | ChinaReviewed |
|---|---|---|
| Legal family | Mixed: Roman-Dutch civil law, English common law, customary law | Socialist civil law |
| System of government | Parliamentary republic | Socialist one-party republic |
| Constitution | Constitution of the Republic of South Africa, 1996 | Constitution of the People's Republic of China |
| In force since | 1996 | 1982 |
| Capital | Pretoria (executive), Cape Town (legislative), Bloemfontein (judicial) | Beijing |
| Official languages | isiZulu, English, Afrikaans, +9 official languages | Standard Chinese (Putonghua) |
| Currency | South African Rand (ZAR) | Renminbi (CNY) |
| Population | 61,000,000 | 1,410,000,000 |
| Division of powers | Parliamentary executive with strong constitutional supremacy; the Constitutional Court may declare conduct of any branch invalid. | Unitary, with a highly asymmetric structure: 23 provinces, five autonomous regions, four directly administered municipalities and two special administrative regions. Hong Kong and Macao operate under 'one country, two systems' with their own Basic Laws, their own courts of final appeal, and legal systems that remain common-law and Portuguese-derived civil-law respectively. Provincial people's congresses may enact local regulations that must not contravene national law. |
| How law is made | Bills are tagged by subject matter, pass the National Assembly and, where provinces are affected, the NCOP, before presidential assent; the President may refer a bill to the Constitutional Court. | The NPC meets in plenary once a year, so the Standing Committee enacts most legislation. A bill is normally read three times under the Legislation Law, with drafts published for public comment — the Civil Code drafts drew over a million submissions. The NPCSC also has power to interpret laws, which it exercises as a substantive lawmaking tool. There is no presidential veto: the President promulgates what the NPC or its Standing Committee has passed. |
| Legal profession | The Legal Practice Act 2014 unified regulation under the Legal Practice Council, retaining the attorney and advocate distinction. | Lawyers are licensed under the Lawyers Law after passing the National Unified Legal Profession Qualification Examination, which since 2018 has also been the common entry route for judges, prosecutors and notaries. Firms are licensed and subject to annual inspection by provincial justice departments, and membership of the All China Lawyers Association is mandatory. A 2012 amendment to the Lawyers Law requires an oath that includes loyalty to the leadership of the Communist Party, and the annual licence renewal is the principal point of leverage over practitioners in politically sensitive work. |
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.