Comparative Analysis of Constitutional Frameworks, Fundamental Rights, And National Constitutional Identity: A Focus on Selected Jurisdictions

2025-07-01T07:10:39+00:00

This study offers a comparative analysis of constitutional frameworks, fundamental rights, and the evolving concept of national constitutional identity across selected jurisdictions. By examining the structures, values, and interpretative approaches of constitutions from both common law and civil law traditions, the research highlights how different countries articulate and safeguard fundamental rights within their unique legal and cultural contexts. The analysis explores the role of constitutional courts, separation of powers, and amendment procedures in shaping the national identity embedded in constitutional texts. Special attention is given to doctrines such as basic structure, proportionality, and judicial review, as well as the impact of supranational entities like the European Union on domestic constitutional autonomy. The findings underscore the dynamic interplay between universal human rights norms and nationally rooted constitutional principles, offering insights into how states reconcile global constitutionalism with local democratic legitimacy and historical narratives.

Licensing of advocacy: the experience of Kazakhstan and Uzbekistan

2025-07-08T10:30:30+00:00

This article presents a comprehensive comparative analysis of legal advocacy licensing mechanisms in Uzbekistan and Kazakhstan. Given its crucial role in safeguarding the rights and freedoms of individuals and legal entities, advocacy is a subject of significant reform in both jurisdictions. The authors investigate how licensing serves as a key instrument for upholding the professionalism and legal competence of practicing lawyers. The research outlines the constitutional underpinnings, legal frameworks, and practical procedures that regulate advocacy in each nation, with particular emphasis on adherence to international standards such as the UN Basic Principles on the Role of Lawyers (1990) and the IBA Standards.

Furthermore, the paper meticulously examines eligibility criteria, encompassing citizenship, legal education, professional examinations or certification, practical internships, and ethical conduct requirements. It also addresses the integration of e-government platforms for the issuance, monitoring, and control of licenses, identifying shared practices and distinctive features concerning administrative procedures, as well as grounds for the refusal, suspension, and termination of licenses. Through a comparison of legal practices and institutional arrangements, this article illustrates the concerted efforts of both Kazakhstan and Uzbekistan to elevate the quality and integrity of legal services via robust, regulated licensing systems. This study offers valuable insights into the contribution of licensing to legal reform and the fostering of a resilient, independent advocacy system.

The American Journal of Political Science Law and Criminology

Comparative Analysis of Constitutional Frameworks, Fundamental Rights, And National Constitutional Identity: A Focus on Selected Jurisdictions

Licensing of advocacy: the experience of Kazakhstan and Uzbekistan