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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
AttributeVanuatuReviewedNamibiaReviewedQatarReviewed
Legal familyMixed common, civil and customary lawMixed Roman-Dutch and English common lawMixed (civil law and Islamic law, with a common-law financial centre)
System of governmentUnitary parliamentary republicSemi-presidential republicUnitary constitutional monarchy
ConstitutionConstitution of the Republic of VanuatuConstitution of the Republic of NamibiaPermanent Constitution of the State of Qatar
In force since198019902004
CapitalPort VilaWindhoekDoha
Official languagesBislama, English, FrenchEnglishArabic
CurrencyVanuatu vatu (VUV)Namibian dollar (NAD)Qatari riyal (QAR)
Population330,0002,600,0003,000,000
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. Eight municipalities administered centrally, with a Central Municipal Council of twenty-nine elected members holding advisory functions over local services only.
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.The Council of Ministers prepares draft legislation, which goes to the Shura Council for review and then to the Emir for ratification and publication in the Official Gazette. The Emir may return a bill to the Council, and may legislate by decree when the Shura Council is not in session, subject to later submission. Following the 2024 amendment the Council is entirely appointed, so there is no elected legislative check.
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.Advocacy before the ordinary courts is reserved to Qatari nationals on the roll of advocates, with foreign lawyers licensed as consultants; onshore pleadings are in Arabic. The QICDRC admits common-law practitioners and sits in English. Attestation before the Ministry of Justice notary is required for powers of attorney, company documents and real property transfers.

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.