A Comparative Analysis on Access to Information in Local Government Administration Systems of South Africa and Türkiye

Access to information is a fundamental right that local administrative systems are compelled to follow when implementing service delivery. Türkiye and South Africa are clear examples of how the administrative system is shaped along the lines of political, social and historical factors. South Africa and Türkiye undertook reforms in their local government laws over the years. This paper strives to analyse how the two administrative systems have performed since 1994 in the case of South Africa and since 2002 in the case of Türkiye. The study draws inspiration from the ‘most similar cases principle’ of Ran Hirschl as a chosen methodology. This ‘most similar cases principle’ used in this paper builds on notion of certain events that have seen transformation in local government administration. This is case of South Africa after 1994, Local authorities had new in line with the new constitution Türkiye in 2002 as part of the EU accession plans which though never took place but still have an impact on new legislation after 2005 under the Local Administration Reform Project. The paper is guided by both international and regional law and will use the events, domestic law, and policy to gauge the level of access to information for residents.