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 | United Arab EmiratesReviewed | KenyaReviewed |
|---|---|---|
| Legal family | Mixed (civil law and Islamic law, with common-law financial free zones) | Mixed (common law, customary law, Islamic law) |
| System of government | Federal elective monarchy | Unitary presidential republic with devolved counties |
| Constitution | Constitution of the United Arab Emirates | Constitution of Kenya |
| In force since | 1971 | 2010 |
| Capital | Abu Dhabi | Nairobi |
| Official languages | Arabic | English, Swahili |
| Currency | UAE dirham (AED) | Kenyan Shilling (KES) |
| Population | 10,500,000 | 55,100,000 |
| Division of powers | Federal, and asymmetric in practice. Seven emirates, of which Dubai and Ras Al Khaimah maintain their own separate local court systems outside the federal judiciary entirely, while the others are integrated into it. Each emirate legislates in its own sphere, and the two financial free zones are separate legal jurisdictions with civil and commercial competence. | 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 | Draft federal legislation is prepared by the Council of Ministers, reviewed by the Federal National Council, approved by the Supreme Council of Rulers and ratified by the President before publication in the Official Gazette. The Federal National Council may propose amendments but the Supreme Council may enact legislation over its objection. Much regulation now issues as federal decree-laws. Free-zone legislation is enacted by the DIFC and ADGM authorities under their own procedures. | 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 | Onshore advocacy before the federal and local courts is reserved to UAE nationals licensed by the Ministry of Justice, with foreign lawyers practising as legal consultants; pleadings onshore must be in Arabic. The DIFC and ADGM courts, by contrast, admit registered practitioners from any common-law jurisdiction and conduct proceedings in English, which is the principal practical reason parties opt into them. Notarisation before a public notary is required for powers of attorney, share transfers and real property dispositions. | 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.