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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 StatesReviewedFranceReviewedJapanReviewedMyanmarReviewed
Legal familyCommon lawCivil lawCivil law with common-law influenceCommon law with codified statutes
System of governmentFederal presidential constitutional republicUnitary semi-presidential republicUnitary parliamentary constitutional monarchyMilitary administration; constitutional order suspended
ConstitutionConstitution of the United StatesConstitution of the Fifth RepublicConstitution of JapanConstitution of the Republic of the Union of Myanmar
In force since1789195819472008
CapitalWashington, D.C.ParisTokyoNaypyidaw
Official languagesEnglish, SpanishFrenchJapaneseBurmese
CurrencyUS Dollar (USD)Euro (EUR)Japanese Yen (JPY)Kyat (MMK)
Population335,000,00068,200,000123,500,00054,500,000
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.Nominally a union of seven regions, seven states, one union territory and six self-administered zones and divisions, each with its own legislature under the 2008 Constitution. In practice the region and state legislatures are suspended or subordinated to the military administration, and chief ministers are appointed centrally.
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.Under the 2008 Constitution, bills passed both chambers and went to the President, with disagreements resolved in joint sitting. Since February 2021 legislation is made by the State Administration Council as law or order, published in the Gazette without legislative passage, and a series of such instruments has amended the Penal Code, the electronic communications law and the criminal procedure code.
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.Advocates and higher-grade pleaders are admitted under the Legal Practitioners Act 1879 and the Bar Council Act 1929, an inherited colonial framework, with the Supreme Court controlling the roll. Independent bar associations formed after 2011 but the Bar Council has long been closely supervised, and lawyers acting in political cases have themselves faced prosecution and disbarment since 2021. Legal aid exists under the Legal Aid Law 2016 but is thinly resourced.

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.