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This study aims to systematise the methodology used in comparative urban planning law and propose primary contexts for comparison in planning law.

This study undertook a review of comparative law methodology discourse and sought to establish connections between the discourse and the field of planning law.

This study argues for establishment of a realistic goal for comparative planning law by focusing on the planning law's modifiability. The goal of comparison in planning law should not be to find universally desirable principles or better solutions. Rather, the goal should be to identify a motive for devising a solution. This is because it is not only difficult to establish legal values that are universally applicable to planning law but also inappropriate to determine superiority of planning laws that have been developed over time by each jurisdiction’s sovereignty and policies on land use. When determining comparable systems for analysis among legal systems that are functionally equivalent, it is important to consider the context of land use relations alongside the comparative analysis to be done. To set realistic goals, the context should not be extended indefinitely but be systematised. Based on the foundational relationship underlying planning law, including the tension between planning authorities and property owners, this study presents five specific contexts for comparative analysis: “Strength of Property Rights,” “Level of Judicial Intervention,” “Plan- or Development-led System,” “Allocation of Planning Power” and “Level of Participation.” Examination of these contexts will allow better understanding of the similarities and differences among different systems and practical application of the results of comparative studies.

This study presents a novel approach to systematising the methodology and framework of comparative planning law.

With the aim of monitoring the existing regulations that are applicable to community of owners facing delinquency, in view of the importance of this issue for the achievement of the Urban Agenda, the present study aims to analyse the most stringent and controversial measures available for the community of owners facing delinquency from a comparative perspective.

The present work addresses the recent legislative amendments that have taken place at national level in this field in several countries and analyses to what extent they have addressed the delinquency problem faced by community of owners.

The current paper shows that, in the end, legal certainty, the prospective legal and economic effects on mortgage lending and constitutional concerns are the underlying reasons behind the reluctance to implement some stringent measures to face delinquency. It also shows that recent amendments concerning alternative dispute resolution mechanisms are a missed opportunity.

Community of owners plays a key role in cities for the achievement of the Urban Agenda, so the periodical contributions from co-owners are paramount to the proper implementation of urban regeneration, energy efficiency and accessibility policies. To this end, the paper analyses existing regulations that are applicable to community of owners facing delinquency, which may increase in the coming years due to the current socioeconomic context.

This paper builds on existing research and goes one step further by addressing the recent legislative amendments that have taken place recently at national level in this field. These measures may serve as an inspiration to other EU legal systems.

This study aims to help develop “business principles for stakeholder capitalism” in two steps. First, the study defines internal logic of three theories of capitalism and two variants within each theory. Second, it examines approaches to integration into modern democratic capitalism. Treating the three theories as substitutes identifies relative strengths and weaknesses; complementarity and partial overlap approaches to integration study the institutional settings within which stakeholder capitalism operates. Empirical outcomes reflect competition between market and stakeholder businesses for participants, with institutional conditions determining the scope of collective action.

The approach aligns three typologies in a unique conceptual arrangement defining the three theories of capitalism: forms of capitalism, potential failures of each form and associated types of goods. The first method examines the internal logic of each theory of capitalism. The second draws on traditional narrative review of references documenting each theory of capitalism and variants together with modern Marxist anti-capitalism.

Three typologies align uniquely with the theories of capitalism, each having two variants. Both variants of stakeholder capitalism are compatible with compassionate capitalism, constitutional government or polycentric governance but not with self-interest capitalism, dictatorship or Marxism. A theory of modern democratic capitalism allocates roles for private, club and social goods with empirically variable mixes occurring across countries. Competition among different types of enterprises provides an empirical test for comparative advantages of stakeholder capitalism. Future research should consider approaches for testing the proposed conceptual scheme in practice concerning capacity to deal with grand challenges, wicked problems and black swan events.

Research approach is limited to logical examination of theories and literature documentation without direct empirical confirmation. The study does not address practical implications for managers and public officials or social implications concerning private incentives, stakeholder cooperation or collective action.

Originality lies in shifting terms of debate about stakeholder capitalism from advocacy of substitute theories to understanding of its relationship to market capitalism and collective action capitalism. Value lies in explaining desirability of theoretical integration of three types of capitalism into a comprehensive framework for modern democratic capitalism.

This paper attempts to explain the phenomenon that Macau has a parliament (Legislative Assembly) and mass suffrage but no political parties.

This paper reviews the development process of “parliament – mass suffrage – political party” in Hong Kong and Macau and tries to explain why Macau does not have a party using comparative research methods.

The political party development of Hong Kong and Macau was influenced by both the (former) colonial power and China, and whether there were political parties in these two regions was the result of the game between China and the (former) colonial power. China hoped to limit the development of party politics in the two regions. Since Britain felt reluctant to cooperate with China, political parties in Hong Kong developed. At the same time, Portugal chose to defer to China, which led Macau not to have a political party.

Existing studies have yet to explain why there are no political parties in Macau, and this paper is the first attempt to do so.

This research paper aimed to study the legal structure of top-performing health governance systems and compare them with the Indonesian health social security system to identify the main differences and provide recommendations for Indonesian and other developing countries’ health policymakers and administrators.

Using formative research with a conceptual approach and statute approach as method in this study. Data was gathered using the document study technique, which studies various documents, especially legal documents related to health law, linked to legal purpose theories. Moreover, the World Health Organization ranking was considered to choose the two countries (France and Singapore) with a high social health security system for comparative analysis. All data collected has been analyzed using a qualitative and theoretical basis. Content analysis was performed by analyzing the legal documents, and the regulatory framework of all three countries was deeply analyzed to draw conclusions and recommendations.

Indonesia has specific laws to implement a social security system in the health sector. However, the lack of the best medical facilities and infrastructure and weak implementation of existing laws were identified as major reasons behind the poor health security system compared to comparative countries. Also, as a developing nation Indonesian Government face budgetary pressures and huge population challenges to meet required standards. Thus, the financing approaches used by Singapore and France may help developing countries meet these challenges effectively. Therefore, there is a dire need to strengthen the social health security system all over the country with amendments to laws and ensure the implementation of prevailing laws and regulations.

Providing understanding related to the social security health system in Indonesia along with a detailed description of the sound social health security system in France and Singapore will further provide an avenue for the researchers to critically analyze this line of study to devise some valuable suggestions further and to draw loopholes in the system.

A comparative approach for legal studies in the health sector is rare. So, this research advanced the social security health system-related literature and legal studies on the health sector by using this comparative approach to develop policy insights and future research directions, which will further help the field to grow.

The abandonment of governmental development projects either after completion or midway completion at the taxpayer’s expense in Ghana could be attributed to lack of effective community engagement (CE). Thus, this study aims to assess CE in development projects by comparing government-sponsored projects to private-sponsored projects.

A qualitative approach was adopted where a multiple case study design was used as a research strategy. Data was collected from selected districts in the Central Region of Ghana by using a semi-structured interview guide and analyzed using the thematic and comparative analysis techniques.

The results reveal that CE in government-funded projects was low, while CE in projects funded by private organizations was high. Three levels of engagement (consultation, participation in decision-making and consent) were also identified. Furthermore, the roles of public participation, including knowledge sharing, collective sense of ownership, among others, were ascertained. Finally, resources constraints, competing interests, lack of information flow, public attitudes toward change and central government/political interference are challenges of CE in development projects.

This study has provided an empirical basis for government and other development agents to draft a policy on CE to serve as a guide, spell out the role of CE, mitigate the challenges of CE and ensure strict compliance to the three levels of engagement.

The aim of this paper is to compare the audit and accountability arrangements of Supreme Audit Institutions (SAIs) internationally.

Building on a theorisation of regulatory space, extended by new audit spaces of public audit, the scope of the research is the 196 SAIs that are full members of the International Organization of Supreme Audit Institutions (INTOSAI). The study is based on documentation review, workshops with a steering panel, a survey of all SAIs (response rate of 64%, being 125 of 196 members), workshops with the seven regions of INTOSAI and discussion at Congress.

The paper suggests that the audit and accountability arrangements for SAIs is underpinned by INTOSAI's global voice, a country's regulatory space and a SAIs organization, capacity and scope that are themes used to structure the comparison. The results show there is diversity in the organization, capacities and scope of SAIs, but also an opportunity for recognising the positive potential of INTOSAI in fulfilling its global voice leveraged from the results of its work with its regions and members.

This is the most comprehensive research study of SAIs and the research underpinning this study enables SAIs to compare themselves regionally and internationally.

This paper aims to analyze and compare attitudes and perceptions of Muslim leadership toward society and politics based on their personal experiences in England and the Netherlands.

This study provides valuable insights into how Muslim leadership experiences socio-political realities from own perspectives. The comparative analysis of Muslim leadership in England and the Netherlands highlights the unique qualities of each community, while also demonstrating shared communal awareness regarding political participation and concerns regarding the rise of Islamophobia and populism.

The study reveals significant differences between Dutch and British Muslim leadership regarding attitudes toward politics. While the Dutch political system enables minorities to have political parties, British leaders prefer peaceful resistance, internal cooperation and voting power for influence. Muslim communities in both countries face similar challenges, such as access to politics, rising Islamophobia and populism. However, there are variations in leadership maturity and attitudes toward communal unification and political participation.

Especially Dutch Muslims were much more open toward cooperation once approached. The biggest challenge was to get into the Muslim communities in England. Even though British Muslims showed a much greater aptitude toward their civic duties, British Muslims were much more careful and wished that interviews were written down instead of being recorded. But once the author was part of the community, community leaders were more accepting and tolerant towards the author's presence. From that point on, to be recommended (snowballing) became easier.

This research shows clearly how different ethnic Muslim communities differ across two different countries. Even though both countries have their own advantages and disadvantages, understanding how civic responsibilities and the progressive development of minority attitudes can be best approached is important to policymakers.

One major social implication is the way minorities perceive social and political equality and how these minority expectations can be met. Research shows that there is much fear and anxiety to growing sentiments of populism and right-wing appraisals. For a better integration and inclusion, a sound assessment of social and religious expectations is crucial.

As far as the author knows, there are no qualitative research studies that compare Muslim minority conditions in the Netherlands and England. This research makes this even more interesting for how to create policy that contributes to a European understanding of Muslim existence in Europe and a common European identity. This is crucial for a more stable and stronger European future.