Question

Make a comparative study of the features of Judiciary in India, UK and USA.

Give a comparative note on the judiciary of India, the USA and the U.K.

Compare the Judicial Systems in India, USA and UK.

Answer 1

Sr. No.	Features	Judiciary in India	Judiciary in UK	Judiciary in USA
1.	Structure	Single, integrated hierarchical structure. Supreme Court → High Courts → Subordinate Courts.	Unified legal system without a written constitution. Supreme Court (2009 onwards) → Court of Appeal → High Court → Magistrates/Crown Court.	Dual system: Federal and State judiciaries. U.S. Supreme Court → Circuit Courts → District Courts (Federal) + Separate State Court Systems.
2.	Basis of Judicial Powers	Powers derived from a written Constitution.	No written constitution; based on Parliamentary sovereignty and common law.	Powers derived from a written Constitution and strengthened by judicial precedent (Marbury v. Madison).
3.	Judicial Review	Limited judicial review; subject to Basic Structure Doctrine.	Very limited; cannot declare laws unconstitutional due to Parliamentary sovereignty.	Broad and absolute power of judicial review; can strike down any law against the Constitution.
4.	Independence of Judiciary	Independent but with executive influence in appointments (collegium system).	High degree of independence; judicial appointments by independent commissions.	Strongly independent; judges appointed by President but confirmed by Senate; life tenure.
5.	Advisory Jurisdiction	Has advisory jurisdiction under Article 143 (President can seek an opinion).	No advisory jurisdiction.	No advisory opinion allowed; courts only decide actual cases.
6.	Tenure of Judges	Retirement at age 65 (Supreme Court) and 62 (High Court).	Retirement at 75.	Lifetime appointment unless impeached or voluntarily retired.