Summary and Outlook

Abstract

The idea of independent ombudsmen controlling the administrative branch has undergone a development in the 20th century, tantamount to an institutional success story. The structure of the institutions differs throughout the various European legal orders. However, the comparative examination of these institutions shows that they have influenced, complemented and enriched one another in various ways. The suggested models of ombudsmen, classified according to powers — the classical model, the model based on the state governed by the rule of law, and the model centred on the protection of human rights — are only rarely found in pure form. In practice, most of the institutions are provided with different combinations of powers, showing characteristics of diverse models. Thus the conclusion can be drawn that the national-political role of ombudsmen nowadays often exceeds the “classical” idea of an informal control of administration by far.