The practice of administrative courts in protecting the rights of citizens: the experience of the United States and the United Kingdom

The article provides a comprehensive analysis of the practice of administrative courts of the United States of America and the United Kingdom in the area of protection of citizens’ rights. The author examines the peculiarities of the organization of administrative justice in both countries, procedural aspects of case consideration, and mechanisms of judicial control over the actions of public administration. The author analyzes the key doctrines and principles applied in the American and British administrative justice systems. Particular attention is paid to the institutions of judicial review, standards of proof, and procedural guarantees of citizens’ rights. The author identifies commonalities and differences in approaches to providing judicial protection in administrative disputes. The key institutions of administrative justice, mechanisms of judicial review of the actions of state bodies, as well as precedents illustrating the effectiveness of these systems are considered. The comparative analysis allows us to identify commonalities and differences, as well as the potential for borrowing experience from other countries, including Ukraine. The study is based on the analysis of legislation, court practice, and scientific sources. The author analyzes the impact of the European Convention on Human Rights on the British practice of administrative justice. The author identifies commonalities and fundamental differences in approaches to providing judicial protection in administrative disputes due to different legal traditions. Based on the analysis, the author identifies the common and distinctive features of the American and British models of administrative justice and formulates conclusions regarding the possibilities of using their positive experience to improve administrative justice in Ukraine with a view to strengthening the guarantees of citizens’ rights and freedoms and establishing the rule of law. The results of the study can be used to improve the national system of administrative justice, develop recommendations for the establishment of specialized chambers, define standards of judicial review, and strengthen procedural guarantees.