УДК 347.963
Nigmatullin A.R.
Abstract The article examines how external review of public duties towards children in alternative care is institutionally organised. Formal legal, functional and comparative methods are used to assess Russia, Portugal, Poland, Norway and New Zealand against seven common criteria. Five functional models are identified, with Russia classified as an integrated prosecutorial model. The study substantiates functional reception: adapting a discrete procedure or safeguard instead of copying a foreign institution as an organisational form.
Keywords: external public oversight, children without parental care, prosecutorial supervision, functional approach, comparative law, ombudsman, inspection, functional reception
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