Judiciary-led Public Interest Litigation in Comparative Perspective:China Model and Its Global Implications
From a comparative perspective,the most notable characteristic of China's public interest litigation(PIL)system is the dominant role played by the People's Procuratorate,which significantly overshadows the involvement of non-governmental organizations.This unique aspect has raised doubts and concerns within the international academic sphere,particularly around issues like local protectionism and state-society relations.Addressing these critiques,this study highlights their Western-centric bias and advocates for the essential role of the judiciary in protecting public interests in the Global South,drawing parallels with examples from India and Brazil.Moreover,it examines how China's PIL system has rapidly expanded,leveraging the procuratorates'advantages in finance,manpower,and political connections,despite the underdevelopment of its societal sector.The paper then explores the implications of this'China model'for other developing nations and considers how insights from other PIL systems can contribute to the refinement of China's approach.The article concludes by discussing how to more effectively articulate China's distinctive perspective in the arena of comparative judicial studies on an international stage.
Public Interest LitigationProcuratorateNongovernmental OrganizationComparative Ju-dicial StudyChina Model
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