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 | LaosReviewed |
|---|---|---|---|---|
| Legal family | Common law | Civil law | Civil law with common-law influence | Socialist civil law |
| System of government | Federal presidential constitutional republic | Unitary semi-presidential republic | Unitary parliamentary constitutional monarchy | Socialist one-party republic |
| Constitution | Constitution of the United States | Constitution of the Fifth Republic | Constitution of Japan | Constitution of the Lao People's Democratic Republic |
| In force since | 1789 | 1958 | 1947 | 1991 |
| Capital | Washington, D.C. | Paris | Tokyo | Vientiane |
| Official languages | English, Spanish | French | Japanese | Lao |
| Currency | US Dollar (USD) | Euro (EUR) | Japanese Yen (JPY) | Kip (LAK) |
| Population | 335,000,000 | 68,200,000 | 123,500,000 | 7,600,000 |
| 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 17 provinces and the Vientiane capital. The 2015 constitutional amendment introduced Provincial People's Assemblies with limited local legislative and supervisory functions, but appointment of governors and fiscal control remain central. |
| 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. | Draft laws are prepared by ministries, reviewed by the Ministry of Justice and the Assembly's committees, and passed by the National Assembly, which meets in ordinary session twice a year. The President promulgates by decree. Because sessions are short and infrequent, a great deal of binding detail is issued as government decrees and ministerial instructions between sittings. |
| 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. | The Lao Bar Association, established under the Law on Lawyers, licenses practitioners after a law degree and a period of supervised practice; the profession remains very small relative to population. Village mediation units handle a large share of civil and family disputes before any court becomes involved, and are formally recognised as part of the justice system rather than an informal alternative to it. Foreign lawyers advise on commercial and investment matters but cannot appear in court. |
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.