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 | NauruReviewed |
|---|---|---|---|---|
| Legal family | Common law | Civil law | Civil law with common-law influence | Common law with customary law |
| System of government | Federal presidential constitutional republic | Unitary semi-presidential republic | Unitary parliamentary constitutional monarchy | Parliamentary republic |
| Constitution | Constitution of the United States | Constitution of the Fifth Republic | Constitution of Japan | Constitution of Nauru |
| In force since | 1789 | 1958 | 1947 | 1968 |
| Capital | Washington, D.C. | Paris | Tokyo | Yaren (seat of government) |
| Official languages | English, Spanish | French | Japanese | Nauruan, English |
| Currency | US Dollar (USD) | Euro (EUR) | Japanese Yen (JPY) | Australian dollar (AUD) |
| Population | 335,000,000 | 68,200,000 | 123,500,000 | 12,500 |
| 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 and highly centralised — Nauru has no second tier of general government. The Nauru Island Council was abolished in 1999, so the state deals directly with citizens, though the 14 districts remain the basis for parliamentary constituencies and the twelve tribes retain social significance in land and title questions. |
| 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 receive three readings in the 19-member chamber and are assented to by the President. Ordinary legislation needs a simple majority, but the entrenched provisions of Part XI require a two-thirds majority and, for the most protected articles, approval at a referendum — the barrier that defeated the 2010 reform proposals. |
| 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 very small fused profession admitted by the Supreme Court under the Legal Practitioners Act 1973, supplemented by pleaders — non-lawyers licensed to appear in the District Court and before the Lands Committee, a practical necessity given the number of resident lawyers. Judicial officers are frequently appointed from Australia, New Zealand or elsewhere in the Pacific. |
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.