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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
AttributeVanuatuReviewedNamibiaReviewedFijiReviewed
Legal familyMixed common, civil and customary lawMixed Roman-Dutch and English common lawCommon law with customary law
System of governmentUnitary parliamentary republicSemi-presidential republicUnitary parliamentary republic
ConstitutionConstitution of the Republic of VanuatuConstitution of the Republic of NamibiaConstitution of the Republic of Fiji
In force since198019902013
CapitalPort VilaWindhoekSuva
Official languagesBislama, English, FrenchEnglishEnglish, Fijian, Fiji Hindi
CurrencyVanuatu vatu (VUV)Namibian dollar (NAD)Fijian dollar (FJD)
Population330,0002,600,000930,000
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.Unitary with 14 administrative regions and elected regional councils, which also constitute the National Council, the upper chamber. Traditional authorities exercise recognised functions over communal land and customary law.Unitary and deliberately centralised. Section 1 declares Fiji a sovereign state whose Parliament legislates for the whole country; there are no provinces with legislative power. The 14 provincial councils and the iTaukei Affairs Board administer indigenous affairs under the iTaukei Affairs Act. Rotuma has a distinct status under the Rotuma Act.
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 pass the National Assembly through three readings, then go to the National Council for review. The Council may confirm, propose amendments, or object; the Assembly can override an objection by a two-thirds majority. The President then assents, and constitutional amendments require two-thirds of both chambers and may never diminish the rights chapter.Bills are introduced in the unicameral Parliament, referred to a standing committee, and pass through second reading, committee and third reading before assent by the President. There is no upper house. A constitutional amendment requires the support of three-quarters of all members of Parliament and then approval by three-quarters of registered voters at a referendum, a threshold that has never been met.
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.A fused profession under the Legal Practitioners Act: a single class of legal practitioner is admitted after a law degree and the Justice Training Centre's postgraduate course, and the Law Society of Namibia regulates practice.A fused profession under the Legal Practitioners Act 2009: practitioners are admitted by the Chief Justice as barristers and solicitors. Most qualify through the University of the South Pacific law degree followed by the Professional Diploma in Legal Practice. Admission and discipline are handled by the Chief Registrar and the Independent Legal Services Commission rather than by the Fiji Law Society, which is a voluntary professional body.

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.