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 | CyprusReviewed |
|---|---|---|---|---|
| Legal family | Common law | Civil law | Civil law with common-law influence | Mixed common law and civil law |
| System of government | Federal presidential constitutional republic | Unitary semi-presidential republic | Unitary parliamentary constitutional monarchy | Unitary presidential republic |
| Constitution | Constitution of the United States | Constitution of the Fifth Republic | Constitution of Japan | Constitution of the Republic of Cyprus |
| In force since | 1789 | 1958 | 1947 | 1960 |
| Capital | Washington, D.C. | Paris | Tokyo | Nicosia |
| Official languages | English, Spanish | French | Japanese | Greek, Turkish |
| Currency | US Dollar (USD) | Euro (EUR) | Japanese Yen (JPY) | Euro (EUR) |
| Population | 335,000,000 | 68,200,000 | 123,500,000 | 1,260,000 |
| 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 districts administered centrally and elected municipalities. In practice the government exercises effective control over roughly the southern two-thirds of the island; the north has been separately administered since 1974 under an entity recognised only by Turkey, and the application of the EU acquis is suspended there under Protocol 10 to the Accession Treaty. The atlas describes the law of the Republic and notes where it is not effectively applied. |
| 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. | Bills are introduced by ministers or members and passed by the House of Representatives. The President may return a law for reconsideration or refer it to the Supreme Court for a constitutionality ruling before promulgation; if the Court finds no conflict, promulgation follows. Laws enter into force on publication in the Official Gazette unless otherwise provided, and EU obligations are frequently implemented by harmonising statute and regulation. |
| 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. | A fused profession of advocates admitted under the Advocates Law after a law degree, the Legal Council examinations and a twelve-month pupillage, with compulsory membership of the Cyprus Bar Association. Many practitioners qualify in the United Kingdom or Greece, and English-language practice is standard in commercial work. Advocates hold a monopoly on court representation and on certifying company documents, and the profession is unusually large per head of population because of the international corporate and trusts business. |
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.