Commission of Article 90 or State Inspection Organization? Comparison of Two Ombudsman Institutions, with Emphasis on Parliamentary Ombudsman of England

In modern legal systems, Ombudsman institution enjoys a non-judicial characteristic which is recognized as a modern supervision tool of the activities of the government, with its main function being focused on defending the rights of individuals. Some of the characteristics governing these institutions, shared by most legal systems, seem noteworthy compared to Commission of Article 90 and State Inspection Organization. Such issues as extensive range of competence in supervision of organizations, public authorities, reporting, informing, non-judicial procedure and functional, individual, organizational and budget independence are some of these minimal characteristics, and employing a comparative approach, the present study demonstrates that considering all the issues mentioned above, compared to State Inspection Organization, Article 90 Commission has more in common with modern Ombudsman institutions. The results of this study can be used in elimination of the shortcomings in State Inspection Organization, enhancement of the characteristics of Article 90 Commission as well as omission of parallel competences.