A Comparative Study of Administrative Tribunal Systems: India, USA, UK, and France

Abstract

The paper explores the historical development of tribunals in various leading nations of the world including USA, UK, France and India.  It provides a comprehensive understanding of how tribunals work in these countries and contribute to the development of their legal system. Administrative tribunals are quasi-judicial bodies that provide speedy and specialized adjudication of disputes. Tribunals are considered as part of regular judicial system in USA and UK. But as the legal framework of both the nations are very different from each other, thus, the tribunals work differently in both the nations. The tribunal system we know today has its origins in France's droit administratif system. France was the first country to develop a structured and comprehensive system in which administrative matters were entirely removed from the jurisdiction of ordinary courts. In India, tribunals have constitutional recognition. Today, there are various tribunals working in different fields. The paper concludes with the observation that one of the features common all the jurisdictions is that the object of establishing the tribunals across the nations remains the same i.e. to provide speedy and effective justice. Also, in most of the jurisdictions, the judiciary has played a proactive role to maintain the rule of law during administrative adjudication.