Accountability

Abstract

Key debates in administrative law often play out within the contours of ‘accountability’. This chapter suggests that the concept of accountability is normatively and analytically useful in comparative administrative law, provided that there is clarity as to the level of abstraction at which the term is used. The chapter proposes a three-tier approach to the concept of accountability—accountability as a political ideal (‘level 1 accountability’), as a specific set of normative commitments (‘level 2 accountability’), and as an empirical phenomenon (‘level 3 accountability’). It argues that the usefulness (and contestability) of comparative approaches will vary as one moves from one tier to the next. Next, it discusses three case studies that illustrate specific institutional manifestations of accountability and demonstrate how the operation of accountability differ based on the background constitutional structure. Finally, the chapter presents certain key challenges to accountability that implicate different tiers of accountability.