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 | ZimbabweReviewed | MoroccoReviewed | IndonesiaReviewed |
|---|---|---|---|
| Legal family | Mixed Roman-Dutch and English common law | Civil law with Islamic law in personal status | Mixed civil, customary and Islamic law |
| System of government | Presidential republic | Constitutional monarchy | Presidential republic |
| Constitution | Constitution of Zimbabwe Amendment (No. 20) | Constitution of the Kingdom of Morocco | Constitution of the Republic of Indonesia 1945 |
| In force since | 2013 | 2011 | 1945 |
| Capital | Harare | Rabat | Jakarta |
| Official languages | English, Shona, Ndebele | Arabic, Tamazight | Indonesian |
| Currency | Zimbabwe Gold (ZWG) | Moroccan dirham (MAD) | Indonesian rupiah (IDR) |
| Population | 16,300,000 | 37,500,000 | 281,600,000 |
| Division of powers | Constitutionally devolved to ten provinces with provincial and metropolitan councils, but implementation has lagged and central government retains effective control of provincial administration and revenue. | Unitary but substantially regionalised since 2015, with twelve regions holding directly elected councils and their own budgets under the advanced regionalisation programme. Regions have executive competences in development planning and transport; they do not legislate. | Unitary but heavily decentralised since the 1999 regional autonomy laws, which devolved most service delivery to some 500 regencies and cities rather than to the 38 provinces. Aceh, Papua and its successor provinces, Yogyakarta and Jakarta hold special autonomy statuses with distinct arrangements โ Aceh includes Sharia jurisdiction and its own political parties; Yogyakarta's governor is hereditary. |
| How law is made | Bills are gazetted, then pass both the National Assembly and the Senate with committee scrutiny, and the Parliamentary Legal Committee reports on whether a bill or statutory instrument is consistent with the constitution โ a step with no direct equivalent in the region. The President assents; constitutional amendments require two-thirds of the membership of each chamber, and some provisions additionally require a referendum. | Bills may be introduced by the head of government or by members of either chamber. They pass through committee and plenary in both houses, with the House of Representatives having the final word where the chambers disagree. Organic laws must be referred to the Constitutional Court before promulgation. The King promulgates statutes by dahir within thirty days, and may ask parliament to reconsider a bill or submit it to referendum. | Bills may originate with the DPR, the President or the DPD on regional matters, and require the agreement of both the DPR and the President โ a genuine joint enactment rather than assent. Once approved the President promulgates; if he does not, the bill becomes law after 30 days. The Constitutional Court may then annul it. The 2020 Job Creation Law was found conditionally unconstitutional for defective process, which forced the enactment of a new law on legislative drafting. |
| Legal profession | A fused profession of legal practitioners registered under the Legal Practitioners Act after a law degree and practical training, regulated by the Law Society of Zimbabwe; senior practitioners may be appointed Senior Counsel. | Avocats are admitted to one of the regional bars and organised nationally through the Association des Barreaux du Maroc; practice before the Court of Cassation requires additional seniority. Notaries and adouls coexist โ the notaire handles conveyancing and company documents in the French tradition, while the adoul draws up marriage and inheritance instruments under Islamic law. Judges are career appointments trained at the Institut Supรฉrieur de la Magistrature. | Advocates are admitted under the Advocate Law 2003 after a law degree, a professional course, the bar examination and two years' apprenticeship, then sworn in by a High Court. PERADI is the principal bar association, though the profession has been divided by competing organisations, and the Constitutional Court has held that multiple bars may coexist while a single body administers admission. Notaries are a separate regulated profession with exclusive competence over deeds of incorporation and land 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 โ the constitutional detail behind a one-line summary is often the part that governs the outcome.