This research article examines how the general legal regime governing petitions of individuals and legal entities should be coordinated with the special administrative-complaint procedure in public service delivery. Using formal legal, comparative, systemic and functional methods, the study analyses Uzbekistan’s legislation on petitions and administrative procedures, the experimental model of Appeal Councils, and Kazakhstan’s Administrative Procedural and Process-Related Code. Three interrelated shortcomings are identified in the general petitions regime: insufficient differentiation of procedural time limits, the absence of detailed criteria for a proper response, and the predominantly internal nature of monitoring. The article shows how these problems change when an ordinary complaint becomes an administrative complaint challenging the outcome of a public service. Because a restorative purpose is also inherent in an ordinary complaint, the proposed distinction relies on the object being challenged, the connection with a specific administrative proceeding, the status of the interested person, the review body’s competence and the legal effect of the decision. An asymmetry is identified between Uzbekistan’s Law on Administrative Procedures, which covers administrative and procedural acts and administrative actions, and the special Appeal Council model focused primarily on administrative acts. The article proposes differentiated time limits for general petitions, a statutory quality standard for responses, institutionalisation of Appeal Councils within the general administrative-review system, and a two-level model of open monitoring combining petition-handling indicators with indicators of actual restoration of rights in public service delivery.
PETITIONS AND ADMINISTRATIVE COM PETITIONS AND ADMINISTRATIVE COMPLAINTS IN PUBLIC SERVICE DELIVERY: PROCEDURAL TIME LIMITS, QUALITY OF DECISIONS AND OPEN MONITORING IN UZBEKISTAN AND KAZAKHSTAN
Published September 2026
Abstract
Language
Русский
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