Comparative Analysis: Key Similarities and Differences

6.1 Accountability Mechanisms

Mechanism	USA	UK	France	China
Legislative oversight	Congressional committees, hearings	Parliamentary select committees, PAC	Parliamentary questions, Senate	NPC (formal, weak)
Judicial review	Strong (Marbury v. Madison, 1803)	Moderate (Courts review admin decisions)	Conseil d'État (Admin courts)	Absent (CPC above courts)
Ombudsman/Lokpal	No federal ombudsman	Parliamentary Commissioner (1967)	Médiateur de la République (1973)	No independent ombudsman
Media freedom	Strong (First Amendment)	Free but regulated (Ofcom)	Moderate	State-controlled
Anti-corruption body	FBI, DOJ, Inspector Generals	ACOBA, Nolan Committee	HATVP (2013)	CCDI (CPC internal)

6.2 Civil Service Neutrality

Aspect	USA	UK	France	China
Political neutrality	Partial (Hatch Act)	Strong tradition	Strong	Non-existent (CPC loyalty required)
Tenure	Career service protected	Yes — permanent secretaries	Yes — corps system	Yes but party reviews
Entry method	Competitive + political	Competitive (FCSR)	Grandes Écoles + exam	Competitive + party
India parallel	Political appointments at top	IAS model derived from here	Prefect ≈ Collector	None — different system

6.3 Fred Riggs and the Ecology of Administration

Riggs emphasised that administrative systems cannot be understood in isolation from their social, economic, and political ecology (environment). His ecological approach explains why transplanting Western models to developing countries often fails:

• Fused model (traditional societies): Administration, politics, economy undifferentiated.
• Prismatic model (transitional — like India): Formal modern structures coexist with traditional practices (nepotism, caste influence, formalism).
• Diffracted model (modern — like USA/UK): Clear specialisation and differentiation.

Sala model: Riggs' term for the administrative sub-system in prismatic societies — the government office (sala) where formal rules coexist with informal nepotistic practices.

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