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	KenyaReviewed
Legal family	Common law with customary law	Mixed French civil law and Islamic law	Mixed (common law, customary law, Islamic law)
System of government	Constitutional monarchy	Federal presidential republic	Unitary presidential republic with devolved counties
Constitution	Act of Constitution of Tonga	Constitution of the Union of the Comoros	Constitution of Kenya
In force since	1875	2001	2010
Capital	Nuku'alofa	Moroni	Nairobi
Official languages	Tongan, English	Comorian, Arabic, French	English, Swahili
Currency	Tongan paʻanga (TOP)	Comorian franc (KMF)	Kenyan Shilling (KES)
Population	105,000	850,000	55,100,000
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.	Presidential system with no Prime Minister, a bicameral Parliament of National Assembly and Senate, 47 county governments with their own assemblies and executives, and an independent judiciary supervised by the Judicial Service Commission.
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 are read three times with committee scrutiny and public participation, which the courts treat as a justiciable requirement. Bills concerning counties must pass both chambers. The President assents or refers the bill back with reservations, which Parliament may override by two-thirds.
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.	Fused: an LLB, the Kenya School of Law advocates training programme, and admission by the Chief Justice produce an advocate of the High Court. The Law Society of Kenya is the professional body; Senior Counsel is the senior rank.

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.