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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
AttributeVanuatuReviewedGermanyReviewedKuwaitReviewed
Legal familyMixed common, civil and customary lawCivil lawMixed (civil law and Islamic law)
System of governmentUnitary parliamentary republicFederal parliamentary republicUnitary constitutional monarchy
ConstitutionConstitution of the Republic of VanuatuGrundgesetz (Basic Law)Constitution of the State of Kuwait
In force since198019491962
CapitalPort VilaBerlinKuwait City
Official languagesBislama, English, FrenchGermanArabic
CurrencyVanuatu vatu (VUV)Euro (EUR)Kuwaiti dinar (KWD)
Population330,00084,400,0004,300,000
Division of powersUnitary 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.Rechtsstaat separation of powers with an unusually strong Federal Constitutional Court that can annul statutes and hear individual constitutional complaints.Unitary. Six governorates administered by appointed governors, with no legislative competence.
How law is madeBills 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.Bills originate with the government, Bundestag or Bundesrat, pass three readings in the Bundestag, then require Bundesrat consent or non-objection; a mediation committee resolves deadlock.Under the constitution as designed, bills passed by the National Assembly required Emiri sanction, and the Emir could return a bill for reconsideration which the Assembly could override by a two-thirds majority. With the Assembly dissolved and the relevant articles suspended since May 2024, legislation is made by Emiri decree on the proposal of the Council of Ministers and published in the Official Gazette (Kuwait Al-Youm).
Legal professionA 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.Two state examinations plus a two-year Referendariat produce the unified jurist qualified as Rechtsanwalt, judge, prosecutor or notary.Advocacy is reserved to Kuwaiti nationals enrolled with the Ministry of Justice and the Kuwait Bar Association, with foreign lawyers acting as consultants and unable to appear; pleadings are in Arabic. Judges are appointed by the Supreme Judicial Council, and a significant proportion of the bench has historically been seconded from other Arab states. Notarial authentication at the Ministry of Justice is required for powers of attorney, property transfers and company formation documents.

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.