The Ombudsman Institution as a Tool for Access to Justice: A Comparative Analysis of the Swedish, Turkish, French, and Polish Models

The ombudsman institution, which ensures the protection of the individual against the administration in modern legal systems, has evolved beyond a mere oversight mechanism to become one of the most effective instruments for the right to access to justice. This study aims to structurally and functionally compare the ombudsman institution through the cases of Sweden, Türkiye, France, and Poland, analyzing how the institution implements principles of equity and rule of law across different legal systems. Adopting a qualitative research methodology, the study examines the constitutional frameworks and up-to-date application data extending to 2024 of the selected countries. The findings reveal that while Sweden represents the classical parliamentary oversight model, France offers an integrated umbrella of rights protection through its defender of rights structure. The Polish model exhibits a jurisdictional/rights-based character, equipped with the authority to appeal to the Constitutional Tribunal. The Ombudsman Institution of Turkiye, on the other hand, has proven its function as a gateway to justice and a social refuge between the administration and the citizen, particularly through its decisions based on equity and the record volume of applications reached during the pandemic period (2020). In conclusion, the study demonstrates that the ombudsman institution plays a vital role in limiting public power and establishing individual justice through extra-judicial means, and that despite structural differences, all models converge on the common ground of freedom to seek rights.