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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 StatesReviewedFranceReviewedJapanReviewedNepalReviewed
Legal familyCommon lawCivil lawCivil law with common-law influenceMixed common law and Hindu customary tradition
System of governmentFederal presidential constitutional republicUnitary semi-presidential republicUnitary parliamentary constitutional monarchyFederal parliamentary republic
ConstitutionConstitution of the United StatesConstitution of the Fifth RepublicConstitution of JapanConstitution of Nepal
In force since1789195819472015
CapitalWashington, D.C.ParisTokyoKathmandu
Official languagesEnglish, SpanishFrenchJapaneseNepali
CurrencyUS Dollar (USD)Euro (EUR)Japanese Yen (JPY)Nepalese rupee (NPR)
Population335,000,00068,200,000123,500,00030,500,000
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.Federal with three tiers: one federal government, seven provinces and 753 local units, each with its own elected assembly and schedule of exclusive powers. This is a genuine constitutional division rather than delegation — local units have taxing and legislative competence — and much post-2015 litigation concerns the boundaries between tiers and the slow transfer of staff and revenue.
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 pass both federal houses, except money bills which originate in the House of Representatives; the President must assent. Constitutional amendment requires a two-thirds majority in both houses and, where a provision affects provincial boundaries or powers, the consent of a majority of provincial assemblies. Provinces and local units legislate within their own schedules.
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 are licensed by the Nepal Bar Council after a law degree and the Council's examination, with tiers of pleader, advocate and senior advocate. A single licence permits appearance at all levels, and the Nepal Bar Association is the professional body. Legal aid is provided under the Legal Aid Act 1997 through district committees, and the Constitution guarantees free legal aid to indigent parties.

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.