COMPARATIVE CONSTITUTIONALISM: LOCAL SELF-GOVERNMENT IN INDIA, SOUTH AFRICA, AND THE UNITED STATES

Povzetek

This paper compares the constitutional rules for local government in India, South Africa, and the United States. It looks at constitutional rules, institutions, and how they work to show differences in local freedom, public involvement, and service provision. India added rules to its constitution that require local governments, while South Africa's constitution makes municipalities a separate government level with development goals. The U.S. lets states decide on local government rules, giving them different levels of freedom. The study shows that how local government is set up in the constitution greatly affects how well it works, with South Africa having the most complete system for cities, even though all three countries face challenges in making them work. This comparison helps understand how constitutional setups affect local democracy and can help improve constitutional rules in different types of governments.