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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
AttributeUnited StatesReviewedFranceReviewedJapanReviewedChinaReviewed
Legal familyCommon lawCivil lawCivil law with common-law influenceSocialist civil law
System of governmentFederal presidential constitutional republicUnitary semi-presidential republicUnitary parliamentary constitutional monarchySocialist one-party republic
ConstitutionConstitution of the United StatesConstitution of the Fifth RepublicConstitution of JapanConstitution of the People's Republic of China
In force since1789195819471982
CapitalWashington, D.C.ParisTokyoBeijing
Official languagesEnglish, SpanishFrenchJapaneseStandard Chinese (Putonghua)
CurrencyUS Dollar (USD)Euro (EUR)Japanese Yen (JPY)Renminbi (CNY)
Population335,000,00068,200,000123,500,0001,410,000,000
Division of powersStrict 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 a highly asymmetric structure: 23 provinces, five autonomous regions, four directly administered municipalities and two special administrative regions. Hong Kong and Macao operate under 'one country, two systems' with their own Basic Laws, their own courts of final appeal, and legal systems that remain common-law and Portuguese-derived civil-law respectively. Provincial people's congresses may enact local regulations that must not contravene national law.
How law is madeA 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.The NPC meets in plenary once a year, so the Standing Committee enacts most legislation. A bill is normally read three times under the Legislation Law, with drafts published for public comment — the Civil Code drafts drew over a million submissions. The NPCSC also has power to interpret laws, which it exercises as a substantive lawmaking tool. There is no presidential veto: the President promulgates what the NPC or its Standing Committee has passed.
Legal professionAdmission 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.Lawyers are licensed under the Lawyers Law after passing the National Unified Legal Profession Qualification Examination, which since 2018 has also been the common entry route for judges, prosecutors and notaries. Firms are licensed and subject to annual inspection by provincial justice departments, and membership of the All China Lawyers Association is mandatory. A 2012 amendment to the Lawyers Law requires an oath that includes loyalty to the leadership of the Communist Party, and the annual licence renewal is the principal point of leverage over practitioners in politically sensitive work.

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.