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Comparative Charter of Human Rights Information



Gareth Griffith has written a comprehensive survey of a Charter of Human Rights in other jurisdictions and found that Australia is the only western state without a Charter of Human Rights.. He found that the few countries without a Charter of Human Rights in any form were Australia, Bhutan, Brunei, and Burma.

The Centre for International and Public Law at the Australian National University has also published papers in a volume called Comparative Perspectives on Bills of Rights.

Canada

Canadian Charter of Rights and Freedoms 1982




Ireland

Chaper XII of the Constitution guarantees fundamental rights.




New Zealand

New Zealand Bill of Rights Act 1990




South Africa

South African Bill of Rights 1996
An interesting feature of the South African Bill of Rights is that it incorporates a number of economic and social rights.




United Kingdom

The Magna Carta
The UK Human Rights Act 1998 (HRA).
The Department for Constitutional Affairs is responsible for the implementation of the Human Rights Act, as well as for developing and maintaining the UK’s position under various treaties.
The Constitution Unit at University College, London contains information on the Human Rights Act and its implementation, including a report on Evidence to the Joint Committee on Human Rights and a discussion paper on the impact of the Human Rights Act on health care.
The Joint Committee on Human Rights terms of reference include the consideration of matters relating to human rights and proposals for remedial orders under the Human Rights Act.
One of the UK leading human rights advocacy groups is Liberty. This website contains excellent information on the HRA. Justice is another UK human rights advocacy group and this website contains excellent information on the HRA.
The Lord Chancellor’s Human Rights Unit website contains information on the HRA, when it came into force, any derogations from the Act because of Terrorism and statistics on the HRA implementation in the courts.
Lord Bingham ‘The Way We Live Now: Human Rights in the New Millennium’.
English 1689 Bill of Rights
The Northern Ireland Human Rights Commission engaged in a consultative process and produced a document in 2001 entitled ‘Making a Bill of Rights for Northern Ireland’.




USSR

Chapter X of the 1936 USSR Constitution contained the Fundamental Rights and Duties of Citizens.




United States

United States Bill of Rights 1791
For historical information about the drafting of the Bill of Rights visit the US National Archives and Records Administration website.




Regional Groups with Human Rights Conventions

Africa

African [ Banjul] Charter on Human and People’s Rights
The Charter is overseen by the African Commission of Human and People’s Rights. The African Court of Human and People’s Rights came into being in January 2004 and has jurisdiction to enforce the Charter as well as other international human rights instruments to which states are party.




Americas

The American Convention on Human Rights is overseen by the Inter-American Court of Human Rights. For judgments and supervision of compliance judgements under the Convention, see the Court’s website.




European Union

The European Convention on Human Rights is enforced by the European Court of Human Rights in Strasbourg. For judgments of the European Court of Human Rights, including a searchable database, see the Court’s website.













Gilbert + Tobin Centre of Public Law, Faculty of Law, UNSW Sydney NSW 2052, Australia 
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