Independence and Enforcement Mechanisms of the Ombudsman in the Parliaments of Iran and the United Kingdom

The Ombudsman is an independent institution that acts as a mediator between citizens and public authorities established by the Constitution and non-governmental public institutions and organizations. It monitors government activities and administrative decisions through non-judicial and innovative means, such as reporting to the parliament, reporting to the applicant, and reporting to the media. It resolves disputes between public and private law entities in order to eliminate injustices resulting from administrative actions. In most legal systems, some of the characteristics of this institution are common. These similarities can be found in Iranian domestic law regarding the Commission of Article 90 of the Constitution and under the Islamic Consultative Assembly, which is more prominent. Issues such as general jurisdiction in monitoring public authorities and organizations, non-judicial process, and independence in terms of functionality and organization are some of these characteristics. In this article, an attempt has been made to compare the Article 90 Commission with the modern Ombudsman institution in the House of Commons of England, taking into account all aspects, using a descriptive-analytical method and a comparative study in a mixed and applied manner. The results obtained are that the Ombudsman institution, as an independent supervisory institution, handles people's complaints in the light of the principle of the rule of law and passes them on to the competent judicial and administrative authorities, or submits a proposal to the parliament to amend the relevant law or amend the existing procedure.