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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 StatesReviewedFranceReviewedJapanReviewedVanuatuReviewed
Legal familyCommon lawCivil lawCivil law with common-law influenceMixed common, civil and customary law
System of governmentFederal presidential constitutional republicUnitary semi-presidential republicUnitary parliamentary constitutional monarchyUnitary parliamentary republic
ConstitutionConstitution of the United StatesConstitution of the Fifth RepublicConstitution of JapanConstitution of the Republic of Vanuatu
In force since1789195819471980
CapitalWashington, D.C.ParisTokyoPort Vila
Official languagesEnglish, SpanishFrenchJapaneseBislama, English, French
CurrencyUS Dollar (USD)Euro (EUR)Japanese Yen (JPY)Vanuatu vatu (VUV)
Population335,000,00068,200,000123,500,000330,000
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.Unitary with decentralised administration. Six provinces — Malampa, Penama, Sanma, Shefa, Tafea and Torba — have councils under the Decentralisation Act with delegated functions. Custom land management is decentralised much further, to area-level Custom Land Tribunals and nakamal-based decision-making under the Custom Land Management Act 2013.
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 are read three times in the single chamber and assented to by the President, who may refer a bill to the Supreme Court if he considers it inconsistent with the Constitution. Ordinary bills need a simple majority of members present, with a quorum of two-thirds. Constitutional amendments require a two-thirds majority of all members; if the amendment touches the status of Bislama, English or French, land, or the republican form of the state, it must also be approved at a national referendum.
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.A fused profession regulated by the Legal Practitioners Act: practitioners are admitted by the Chief Justice and licensed by the Law Council. The University of the South Pacific's law school is in Port Vila, so many Pacific lawyers train in Vanuatu. Practitioners may need to work in Bislama, English or French depending on the client and the court file, and the Public Solicitor is a constitutional office rather than a discretionary aid scheme.

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.