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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
AttributeTongaReviewedKuwaitReviewedSpainReviewed
Legal familyCommon law with customary lawMixed (civil law and Islamic law)Civil law
System of governmentConstitutional monarchyUnitary constitutional monarchyUnitary parliamentary constitutional monarchy
ConstitutionAct of Constitution of TongaConstitution of the State of KuwaitSpanish Constitution
In force since187519621978
CapitalNuku'alofaKuwait CityMadrid
Official languagesTongan, EnglishArabicSpanish
CurrencyTongan paสปanga (TOP)Kuwaiti dinar (KWD)Euro (EUR)
Population105,0004,300,00048,400,000
Division of powersUnitary. 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.Unitary. Six governorates administered by appointed governors, with no legislative competence.A constitutional monarchy with the King as head of state, an executive led by the President of the Government, a bicameral parliament and an independent judiciary, overlaid by extensive regional self-government.
How law is madeBills 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.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 pass both chambers of the Cortes Generales, with the Congress of Deputies able to override the Senate, and receive royal assent.
Legal professionLaw 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.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.Abogados belong to local bar associations (colegios de abogados); procuradores represent parties procedurally and notaries authenticate deeds and company acts.

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.