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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 StatesReviewedFranceReviewedJapanReviewedGuyanaReviewed
Legal familyCommon lawCivil lawCivil law with common-law influenceMixed common and civil law
System of governmentFederal presidential constitutional republicUnitary semi-presidential republicUnitary parliamentary constitutional monarchyUnitary presidential republic
ConstitutionConstitution of the United StatesConstitution of the Fifth RepublicConstitution of JapanConstitution of the Co-operative Republic of Guyana
In force since1789195819471980
CapitalWashington, D.C.ParisTokyoGeorgetown
Official languagesEnglish, SpanishFrenchJapaneseEnglish
CurrencyUS Dollar (USD)Euro (EUR)Japanese Yen (JPY)Guyanese dollar (GYD)
Population335,000,00068,200,000123,500,000810,000
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 ten regions run by elected Regional Democratic Councils and a Local Government Commission. Indigenous Amerindian communities hold titled village lands under the Amerindian Act 2006 with village councils exercising defined local authority.
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.Bills are read three times in the National Assembly, considered in committee, and assented to by the President, who may withhold assent and return a bill once. Money bills are the executive's initiative. Ordinary amendment of the Constitution needs two-thirds of all elected members; deeply entrenched articles additionally require approval at a referendum.
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.A fused profession: an attorney-at-law both advises and appears. Qualification is normally an LLB from the University of Guyana followed by the Legal Education Certificate from a Council of Legal Education school, then admission by the High Court. The Guyana Bar Association represents practitioners while discipline rests with the courts.

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.