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	TongaReviewed	ComorosReviewed	IndonesiaReviewed
Legal family	Common law with customary law	Mixed French civil law and Islamic law	Mixed civil, customary and Islamic law
System of government	Constitutional monarchy	Federal presidential republic	Presidential republic
Constitution	Act of Constitution of Tonga	Constitution of the Union of the Comoros	Constitution of the Republic of Indonesia 1945
In force since	1875	2001	1945
Capital	Nuku'alofa	Moroni	Jakarta
Official languages	Tongan, English	Comorian, Arabic, French	Indonesian
Currency	Tongan paʻanga (TOP)	Comorian franc (KMF)	Indonesian rupiah (IDR)
Population	105,000	850,000	281,600,000
Division of powers	Unitary. The Legislative Assembly legislates for the whole kingdom, and the island divisions of Tongatapu, Vava'u, Ha'apai, 'Eua and the Niuas are administrative districts headed by governors. Below that, town and district officers are elected under the Fakafekau'aki and District and Town Officers Act.	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.	Unitary but heavily decentralised since the 1999 regional autonomy laws, which devolved most service delivery to some 500 regencies and cities rather than to the 38 provinces. Aceh, Papua and its successor provinces, Yogyakarta and Jakarta hold special autonomy statuses with distinct arrangements — Aceh includes Sharia jurisdiction and its own political parties; Yogyakarta's governor is hereditary.
How law is made	Bills pass three readings in the Legislative Assembly and require the King's assent, which is a real rather than purely formal step. Ordinary bills need a simple majority. Amendments to the Constitution require a majority in the Assembly at three separate readings and the consent of the King and Privy Council, and clause 79 forbids any amendment affecting the law of liberty, the succession to the throne or the titles and hereditary estates of the nobles.	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 may originate with the DPR, the President or the DPD on regional matters, and require the agreement of both the DPR and the President — a genuine joint enactment rather than assent. Once approved the President promulgates; if he does not, the bill becomes law after 30 days. The Constitutional Court may then annul it. The 2020 Job Creation Law was found conditionally unconstitutional for defective process, which forced the enactment of a new law on legislative drafting.
Legal profession	Law practitioners are admitted by the Chief Justice and licensed under the Law Practitioners Act, with the Tonga Law Society as the professional body. Most qualify overseas or at the University of the South Pacific. A practitioner working on land must know the Land Act's allotment system rather than general property law, because the constitutional bar on selling land means conveyancing in the ordinary sense does not exist.	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.	Advocates are admitted under the Advocate Law 2003 after a law degree, a professional course, the bar examination and two years' apprenticeship, then sworn in by a High Court. PERADI is the principal bar association, though the profession has been divided by competing organisations, and the Constitutional Court has held that multiple bars may coexist while a single body administers admission. Notaries are a separate regulated profession with exclusive competence over deeds of incorporation and land transfers.

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.