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The Public Sector Ombudsman in Greater China: Four “Chinese” Models of Administrative Supervision

Among the challenges facing Greater China, the ombudsman is rarely, if ever, considered one of them. Yet this relatively innocuous institution can, under the right conditions, contribute much that is beneficial to standards in public administration. This is the first Article to contrast the models of public sector ombudsman in Mainland China, Hong Kong, Macau, and Taiwan, drawing comparisons on such features as institutional function, constitutional and legal status, relationship with the executive branch, process, substantive powers, effectiveness and transparency. Even in a region as politically, constitutionally and economically associated as Greater China, four diverse models of ombudsman coexist. They display sharp differences from systemic function to institutional culture, and as the region is now on a path of convergence, these are differences which may soon have to be reconciled. That reconciliation would, as this Article shows, require a major reconceptualization and reconfiguration of administrative supervision in at least three of the jurisdictions under review. * Associate Professor, City University of Hong Kong; Legal Adviser to the Ombudsman of Hong Kong (this Article is not written in the latter capacity). I would like to thank Jyh-An Lee and Yu Qi for helpful comments on a draft of this Article, and Xu Qian for research assistance. I am also grateful to colleagues at the Constitutional and Administrative Law Centre at Peking University and the Asian Law Centre and Centre for Comparative Constitutional Law at the University of Melbourne for constructive feedback on this research. Published by Penn Law: Legal Scholarship Repository, 2018 436 U. Pa. J. Int’l L. [Vol. 39:2