Mechanizm ochrony praw człowieka w systemie Rady Europy i w systemie interamerykańskim (teoretyczna analiza prawnoporównawcza)
The mechanism of human rights protection in the Council of Europe and in the inter-American system (a theoretical legal-comparative analysis)

Summary/Abstract: Analysis of dissimilarities in inter- American and European protection systems of regional human rights in contexts of their efficiency is the subject of this article. The differences in both systems concern a catalogue of warranted law both guaranteed and individual, analyzed by authors, elements of check mechanisms that provide their efficiency and reality i.e. institution of individual complaint, range of jurisdiction of subjective tribunal and implementation of local sentence law. Catalogue of warranted human rights in American convention is more extensive in comparison to European convention since individual rights are more detailed (by showing criteria of their realization). With similar procedure principles in both systems, the problem of sentence implementation on grounds of state legislation directly decreases efficiency of the protection system of human rights in inter- American system. Legal- comparative analysis of individual elements in both systems proves that the present form of regulation of both systems predetermines high level of efficiency of solution accepted by Council of Europe.

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