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 | Sri LankaReviewed |
|---|---|---|---|---|
| Legal family | Common law | Civil law | Civil law with common-law influence | Mixed civil, common and customary law |
| System of government | Federal presidential constitutional republic | Unitary semi-presidential republic | Unitary parliamentary constitutional monarchy | Semi-presidential republic |
| Constitution | Constitution of the United States | Constitution of the Fifth Republic | Constitution of Japan | Constitution of the Democratic Socialist Republic of Sri Lanka |
| In force since | 1789 | 1958 | 1947 | 1978 |
| Capital | Washington, D.C. | Paris | Tokyo | Sri Jayawardenepura Kotte |
| Official languages | English, Spanish | French | Japanese | Sinhala, Tamil, English |
| Currency | US Dollar (USD) | Euro (EUR) | Japanese Yen (JPY) | Sri Lankan rupee (LKR) |
| Population | 335,000,000 | 68,200,000 | 123,500,000 | 22,200,000 |
| 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 a devolved provincial layer created by the Thirteenth Amendment of 1987, which established nine provincial councils with legislative competence over a devolved list. Devolution has been contested and uneven; provincial councils have operated without elections since 2018, and the Northern and Eastern provinces' status was central to the conflict that ended in 2009. |
| 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 are published in the Gazette at least seven days before first reading, which is the trigger for the one-week window to petition the Supreme Court. A bill inconsistent with the Constitution needs a two-thirds majority, and in some cases a referendum. After enactment the Speaker's certificate is conclusive and the Act is immune from challenge. |
| 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 single fused profession: attorneys-at-law are admitted and enrolled by the Supreme Court after the Sri Lanka Law College course and examinations, or a recognised law degree plus the final examination. The historic split between advocates and proctors was abolished in 1974. President's Counsel is a distinction conferred by the President. The Bar Association of Sri Lanka represents the profession, and attorneys have rights of audience in all courts from admission. |
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.