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
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| Attribute | ZambiaReviewed | KenyaReviewed | MadagascarReviewed |
|---|---|---|---|
| Legal family | English common law with customary law | Mixed (common law, customary law, Islamic law) | French civil law with customary law |
| System of government | Presidential republic | Unitary presidential republic with devolved counties | Semi-presidential republic |
| Constitution | Constitution of Zambia | Constitution of Kenya | Constitution of the Fourth Republic |
| In force since | 1991 | 2010 | 2010 |
| Capital | Lusaka | Nairobi | Antananarivo |
| Official languages | English | English, Swahili | Malagasy, French |
| Currency | Zambian kwacha (ZMW) | Kenyan Shilling (KES) | Malagasy ariary (MGA) |
| Population | 20,600,000 | 55,100,000 | 30,300,000 |
| Division of powers | Unitary with ten provinces and decentralised district councils. Chiefs administer customary land through the House of Chiefs, which advises on matters of custom and tradition. | Presidential system with no Prime Minister, a bicameral Parliament of National Assembly and Senate, 47 county governments with their own assemblies and executives, and an independent judiciary supervised by the Judicial Service Commission. | Unitary with a decentralised structure of 23 regions and communes. Successive constitutions have promised fuller decentralisation, including provincial autonomy, which has not been implemented. |
| How law is made | Bills are published in the Gazette, read three times in the National Assembly with committee scrutiny, and presented for presidential assent. Constitutional amendments require two-thirds of the membership, and amendments touching the bill of rights or the sovereignty provisions additionally require a national referendum — the reason several attempted rights reforms have stalled. | Bills are read three times with committee scrutiny and public participation, which the courts treat as a justiciable requirement. Bills concerning counties must pass both chambers. The President assents or refers the bill back with reservations, which Parliament may override by two-thirds. | Bills originate with the government or members of either chamber, are examined in committee, and must pass both the National Assembly and the Senate; the Assembly prevails on disagreement. The Haute Cour Constitutionnelle may review a law before promulgation, and organic laws must be referred to it as a matter of course. |
| Legal profession | A fused profession of practitioners admitted after a law degree and the Zambia Institute of Advanced Legal Education programme, regulated by the Law Association of Zambia; senior practitioners may be appointed State Counsel. | Fused: an LLB, the Kenya School of Law advocates training programme, and admission by the Chief Justice produce an advocate of the High Court. The Law Society of Kenya is the professional body; Senior Counsel is the senior rank. | Avocats admitted to the Ordre des avocats de Madagascar after a law degree and professional training, alongside notaires for authenticated instruments and huissiers for service and enforcement — the standard French division of functions. |
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.