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 StatesReviewed | FranceReviewed | JapanReviewed | BruneiReviewed |
|---|---|---|---|---|
| Legal family | Common law | Civil law | Civil law with common-law influence | Mixed common law and Islamic law |
| System of government | Federal presidential constitutional republic | Unitary semi-presidential republic | Unitary parliamentary constitutional monarchy | Absolute monarchy |
| Constitution | Constitution of the United States | Constitution of the Fifth Republic | Constitution of Japan | Constitution of Brunei Darussalam |
| In force since | 1789 | 1958 | 1947 | 1959 |
| Capital | Washington, D.C. | Paris | Tokyo | Bandar Seri Begawan |
| Official languages | English, Spanish | French | Japanese | Malay, English |
| Currency | US Dollar (USD) | Euro (EUR) | Japanese Yen (JPY) | Brunei dollar (BND) |
| Population | 335,000,000 | 68,200,000 | 123,500,000 | 450,000 |
| Division of powers | Strict separation between Congress, the President and the federal judiciary, checked by veto, impeachment, advice-and-consent over appointments, and judicial review established in Marbury v. Madison (1803). | Semi-presidential: the President holds reserved powers over defence and foreign affairs; the Government answers to Parliament. The Conseil constitutionnel reviews statutes before promulgation and, since 2008, on referral from litigation. | Parliamentary government with the Cabinet collectively responsible to the Diet, and a Supreme Court holding the final power of constitutional review. | Unitary, with four districts administered by district officers reporting to the Ministry of Home Affairs. No federal or devolved tier; village and mukim headmen have recognised consultative functions. |
| How law is made | A bill is introduced in either chamber, referred to committee, reported, debated and voted. It must pass both chambers in identical text, then be signed by the President or survive a veto by a two-thirds vote in each chamber. | A projet or proposition de loi shuttles between the chambers; the Assembly can be given the last word. Organic laws and constitutional amendments follow stricter routes. | Most bills are Cabinet-sponsored, drafted by ministries and reviewed by the Cabinet Legislation Bureau, then passed by both houses; the lower house can override the upper by a two-thirds majority. | In form, bills are introduced in the Legislative Council and assented to by the Sultan. In practice the significant instruments are Orders made by the Sultan under the emergency proclamation, which take effect on publication in the Government Gazette without Council passage. The Syariah Penal Code Order 2013 was enacted this way. |
| Legal profession | Admission is state-by-state: an accredited JD, a state bar examination, and a character and fitness review. There is no split between barristers and solicitors. | Avocats qualify through a CRFPA examination and the CAPA. Notaires, huissiers and avocats aux Conseils are separate regulated professions. | Candidates pass the national bar examination, then complete a year at the Legal Training and Research Institute before qualifying as bengoshi, judge or prosecutor. | Advocates and solicitors are admitted by the High Court under the Legal Profession Act, generally after qualifying in England, Malaysia, Singapore or Australia and completing local requirements. The profession is small — a few hundred practitioners — and foreign counsel may be admitted ad hoc for particular cases. Syariah practice is a separate track: Syariah lawyers are certified under the Syariah Courts Act and appear only in the Syariah hierarchy, so a matter that crosses both systems needs two sets of representation. |
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.