Abstract
The purpose of this study was to clarify the relationship between comparative law and the comparative-legal method under conditions of legal globalisation and to determine the capacity of comparative analysis to assess the compliance of national legislation and law enforcement practice with international human rights standards. The study employed comparative-legal analysis at the macro- and micro-levels, the functional approach, and the comparison of “law on the books” with “law in action”. The empirical basis included constitutions, sectoral legislation, strategic legal documents, international human rights instruments, and reports on their practical implementation in Kyrgyzstan, Kazakhstan, and Uzbekistan. It was established that comparative law functions as an independent field of legal scholarship, whereas the comparative-legal method serves as an instrument for identifying similarities, differences, and functional consequences of legal regulation. The analysis revealed that formal incorporation of international human rights standards does not necessarily ensure their effective implementation. In all three countries, constitutional guarantees coexist with institutional dependence, administrative discretion, and restrictions affecting civil liberties. Kyrgyzstan adopted legislation on “foreign representatives”, Kazakhstan introduced differentiated oversight of recipients of foreign funding, and Uzbekistan retained prior state authorisation for foreign grants. Although these mechanisms differ in legal form, they may restrict freedom of association, expression, public participation, and the activities of human rights organisations. The study demonstrated that comparative analysis makes it possible to identify the gap between declared rights and actual law enforcement practice and to distinguish genuine legal convergence from formal legislative borrowing. The findings may be used in assessing legal reforms, monitoring compliance with international human rights obligations, and improving national mechanisms for protecting civil liberties