Comparative Human Rights Law: A Comparative Overview of ECHR v ACHR v ACHPR

This paper offers a direct comparison between the three leading regional instruments of human rights protection in the world, namely the European Convention on Human Rights, the American Convention on Human Rights and the African Charter on Peoples” and Human Rights. The comparison is one which is based predominantly on the text of these regional instruments, even though inroads to case law analysis are made as appropriate and where necessary, especially where the deployment of case law would be beneficial to the reader in the interpretation of the comparable matter. Methodologically, this is a comparison of differences and similarities in relation to the legal texts in question. As such, for reasons of economy of space, the author has chosen to focus on the functional approach of the comparative legal analysis. Yet certain references to contextual matter, in the comparison in question, will be made where this would enhance the reader’s appreciation of the development of the jurisprudence behind the compared legal texts.