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Abstract


OMBUDSMAN INSTITUTIONS OF SWEDEN, ENGLAND, FRANCE AND TURKEY: A COMPARATIVE ANALYSIS

Generally, Ombudsman institution which was established with very broad authority in the Nordic countries has created a more balanced structurein Sweden. Although England, based on many years with well-established parliamentary system and the judicial integrity as a country in the first place stand against the creation of the ombudsman institution, in question institution was established with limited authority in 1967. France which is as the cradle of the administrative judiciary, the creation of the ombudsman was considered unnecessary previously, but ombudsman institutionwhose appoinment had been realized under the influence of executive power has been included into the administrative system.

Ombudsman Institution which has been attempted to establish approximatelyfor twenty years, is regulatedconstitutionally under the name of Ombudsmanwith replacement of certain provisions of Constitution as result of the plebiscite in 2010.Ombudsman has been created with the name Ombudsman Institution with the adoption of Ombudsman Institution Act no. 6328 in Turkey Grand National Assembly on14.06.2012.

This study focused that point out deficiencies of the Ombudsman and make compare that Sweden, England, France and Turkey's institution; from percpective of differences and similarities between Ombusdman's attributes, selection and assignment processes, duty times, dismissal procedure, audit areas and audit start procedures. According to this context, the study was formed based on documents via theoric framework.



Keywords
Ombudsman, Public Supervising, The Control of Administration



Kaynakça

Gelişmiş Arama


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