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
Clear selectionAfghanistanAlbaniaAlgeriaAndorraAngolaAntigua and BarbudaArgentinaArmeniaAustraliaAustriaAzerbaijanBahrainBangladeshBarbadosBelarusBelgiumBelizeBeninBhutanBoliviaBosnia and HerzegovinaBotswanaBrazilBruneiBulgariaBurkina FasoBurundiCambodiaCameroonCanadaCape VerdeCentral African RepublicChadChileChinaColombiaComorosCosta RicaCroatiaCubaCyprusCzechiaDR CongoDenmarkDjiboutiDominicaDominican RepublicEcuadorEgyptEl SalvadorEquatorial GuineaEritreaEstoniaEswatiniEthiopiaFijiFinlandFranceGabonGambiaGeorgiaGermanyGhanaGreeceGrenadaGuatemalaGuineaGuinea-BissauGuyanaHaitiHoly See (Vatican City)HondurasHungaryIcelandIndiaIndonesiaIranIraqIrelandIsraelItalyIvory CoastJamaicaJapanJordanKazakhstanKenyaKiribatiKuwaitKyrgyzstanLaosLatviaLebanonLesothoLiberiaLibyaLiechtensteinLithuaniaLuxembourgMadagascarMalawiMalaysiaMaldivesMaliMaltaMarshall IslandsMauritaniaMauritiusMexicoMicronesiaMoldovaMonacoMongoliaMontenegroMoroccoMozambiqueMyanmarNamibiaNauruNepalNetherlandsNew ZealandNicaraguaNigerNigeriaNorth KoreaNorth MacedoniaNorwayOmanPakistanPalauPalestinePanamaPapua New GuineaParaguayPeruPhilippinesPolandPortugalQatarRepublic of the CongoRomaniaRussiaRwandaSaint Kitts and NevisSaint LuciaSaint Vincent and the GrenadinesSamoaSan MarinoSaudi ArabiaSenegalSerbiaSeychellesSierra LeoneSingaporeSlovakiaSloveniaSolomon IslandsSomaliaSouth AfricaSouth KoreaSouth SudanSpainSri LankaSudanSurinameSwedenSwitzerlandSyriaSรฃo Tomรฉ and PrรญncipeTajikistanTanzaniaThailandThe BahamasTimor-LesteTogoTongaTrinidad and TobagoTunisiaTurkeyTurkmenistanTuvaluUgandaUkraineUnited Arab EmiratesUnited KingdomUnited StatesUruguayUzbekistanVanuatuVenezuelaVietnamYemenZambiaZimbabwe
| Attribute | VanuatuReviewed | LesothoReviewed | HaitiReviewed |
|---|---|---|---|
| Legal family | Mixed common, civil and customary law | Mixed Roman-Dutch and English common law | Civil law |
| System of government | Unitary parliamentary republic | Parliamentary constitutional monarchy | Unitary semi-presidential republic |
| Constitution | Constitution of the Republic of Vanuatu | Constitution of Lesotho | Constitution de la Rรฉpublique d'Haรฏti |
| In force since | 1980 | 1993 | 1987 |
| Capital | Port Vila | Maseru | Port-au-Prince |
| Official languages | Bislama, English, French | Sesotho, English | French, Haitian Creole |
| Currency | Vanuatu vatu (VUV) | Lesotho loti (LSL) | Haitian gourde (HTG) |
| Population | 330,000 | 2,300,000 | 11,600,000 |
| Division of powers | Unitary with decentralised administration. Six provinces โ Malampa, Penama, Sanma, Shefa, Tafea and Torba โ 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. | Unitary with ten districts, and a recognised hierarchy of chiefs exercising customary functions over land allocation and local dispute resolution. The Senate includes the twenty-two principal chiefs ex officio. | Unitary with constitutionally recognised decentralisation to 10 departments, arrondissements and communes, and to the communal section as the smallest territorial unit. In practice the elected local bodies are largely unfilled and replaced by appointed interim commissions. |
| How law is made | 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. | Bills pass three readings in the National Assembly, go to the Senate for review, and receive royal assent. The Senate can delay but not indefinitely block ordinary bills. Amendments to entrenched constitutional provisions require a two-thirds majority and, for the most protected clauses, a referendum. | Under the 1987 Constitution bills pass both chambers and are promulgated by the President, who may return a text once for reconsideration. With Parliament not sitting, measures have been issued as executive decrees since 2020 โ a practice widely criticised as lacking constitutional foundation, and a key reason to check the current status of any recent instrument before relying on it. |
| Legal profession | 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 split profession in form โ advocates and attorneys are separately admitted under the Legal Practitioners Act โ though in practice many practitioners hold both admissions; the Law Society of Lesotho regulates the attorneys' branch. | Advocates are admitted to one of the departmental bars (Ordre des avocats), most prominently the Port-au-Prince bar, after a law degree and a period of pupillage. Notaries hold a separate public office with exclusive competence over authentic acts including land transfers, which matters greatly given widespread informality in land title. |
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 โ the constitutional detail behind a one-line summary is often the part that governs the outcome.