Comparative Perspective Research Articles

Legal Study on the Validity of Electronic Notarial Deeds in Indonesia: Regulatory Analysis and Practical Implications

This study aims to evaluate the validity of electronic notary deeds in the context of Indonesian law, analyze their implementation challenges, and compare regulations with other countries that have adopted similar systems. The method used is a normative juridical approach with an analysis of various regulations, such as the Notary Position Law, the ITE Law, and the Government Regulation on Electronic Systems and Transactions. In addition, the study draws on the study of international literature and regulations, such as the eIDAS Regulation in the European Union, to offer a comparative perspective. Data analysis was carried out qualitatively through descriptive and comparative techniques. The findings show that regulations in Indonesia, while providing a basic foundation for electronic documents, still require more specific adjustments to accommodate the digitization of notary deeds. Key challenges include aspects of legal validity, digital security, and resistance to traditional legal culture. In contrast, the experiences of developed countries such as the European Union and Japan highlight the importance of reliable technological infrastructure and adaptive regulations to ensure successful implementation. The conclusion of the study emphasizes the need to harmonize national regulations with international standards as well as strengthen technological capacity and notary understanding of digital systems. The study recommends the development of a more integrated legal framework, improved digital security, and public and professional education to accelerate the transition to electronic notary deeds in Indonesia.

Environmental Education and International Legal Frameworks: A Comparative Analysis and Social Impact Perspective

The attitude, skills, and behaviour of any country depend on the level of Education. Focusing on environmental knowledge positively changes environmental attitudes and influences ecological practices. Education is a crucial element in facing climate change. Educational institutions, generally, family and school, can affect students' understanding of their role as environmental stewards by encouraging them to participate in outdoor learning programs and supporting youth who engage in activism. The international organizations whose objective is related to the environment, the European Union, etc, are key players in promoting climate action and sustainable development, affirming some crucial principles mentioned by international jurisprudence. Environmental Education's priority is to balance human and economic well-being, which is integrated with cultural traditions and respect for the earth's natural resources. This paper aims to find the best practices and illustrate how Education can empower citizens to act toward positive environmental and social change. The challenge is integrating ecological consciousness into educational practice, considering that environmental Education is most effective by implementing interactive methods that connect the environment with the community's culture, tradition, and lifestyle. Received: 12 December 2024 / Accepted: 30 April 2025 / Published: 08 May 2025

Brassinosteroid Signaling Dynamics: Ubiquitination-Dependent Regulation of Core Signaling Components

Brassinosteroids (BRs) are essential phytohormones that orchestrate various stages of plant growth and development. The BR signaling cascade is mediated through a phosphorylation network involving sequential activation of the plasma membrane-localized receptor kinase Brassinosteroid-Insensitive 1 (BRI1), the cytoplasmic kinase Brassinosteroid-Insensitive 2 (BIN2), and the transcription factors BRI1-EMS suppressor 1 (BES1) and Brassinazole-Resistant 1 (BZR1). These transcription factors activate thousands of nuclear genes. Recent evidence highlights that ubiquitination has emerged as an equally pivotal mechanism that dynamically controls the BR signaling pathway by modulating the activity, subcellular localization, and protein stability of these core signaling components. In this review, we systematically analyze the central role of ubiquitination in determining the function, localization, and degradation of these proteins to fine-tune the outputs of BR signaling. We provide comparative perspectives on the functional conservation and divergence of ubiquitin-related regulatory components in the model plant Arabidopsis versus other plant species. Furthermore, we critically evaluate current knowledge gaps in the ubiquitin-mediated spatiotemporal control of BR signaling, offering insights into potential research directions to elucidate this sophisticated regulatory network.

The Dark Side of Democracy: New Empirical Evidence of Its Effect on Banking Stability

ABSTRACTDue to less settled securities exchanges, the main source of risk of the financial system in Africa is characterized by its most significant aspects being the banking sector in particular. Consequently, the overall stability of the financial system can be ensured by the stability of the banking sector. Furthermore, the greatest number of nations in Africa has historically been viewed as weak democracies. Thus, the purpose of this article is to examine the impact of democracy on banking stability in Africa. The approach includes data for 34 African countries from 2004 to 2019, and OLS and IV‐Tobit estimation techniques. Our diagnosis shows that democracy harms banking stability in Africa, with the results robust across different types of democracy, levels of political stability, proximity to the sea, and alternative indicators of banking stability. This affirms that democracy is not good for every sector's stability, especially for the banking sector. Policy implications are discussed.Related ArticlesAideyan, Osaore. 2016. “Political and Institutional Prerequisites for Monetary Union: Assessing Progress in the Economic Community of West African States (ECOWAS).” Politics & Policy 44(6): 1192–212. https://doi.org/10.1111/polp.12183.Asongu, Simplice A., Joseph Nnanna, and Vanessa S. Tchamyou. 2021. “Finance, Institutions, and Private Investment in Africa.” Politics & Policy 49(2): 309–51. https://doi.org/10.1111/polp.12395.Scarlato, Margherita, and Giorgio d'Agostino. 2019. “The Political Dimension of Cash Transfers in Latin America and Sub‐Saharan Africa: A Comparative Perspective.” Politics & Policy 47(6): 1125–55. https://doi.org/10.1111/polp.12332.

Regulating the Unregulated: Legal Frontiers in the Age of Cryptocurrency

Widespread adoption of cryptocurrency on a global scale has created new and unique challenges for lawmakers. The rise of decentralized digital assets are reshaping finance, trade and investment, and the absence of consistent regulation exposes consumers to fraud and money laundering, market manipulation, and consumer protection adherence risks. In this paper, we have gauged the available legal tools in the cryptocurrency era and have reviewed cross-border regulatory regimes, jurisdictional challenges, and technological responses and have identified the road to a credible regulatory framework. Relying upon qualitative analysis and a comparative legal perspective, this article underscores the necessity that for the preservation of stability and security of digital financial systems the right mix of innovation and regulation ought to be struck.

Correction to ‘Cotton cultivation under colonial rule in India in the nineteenth century from a comparative perspective’

Correction to ‘Cotton cultivation under colonial rule in India in the nineteenth century from a comparative perspective’

Implementation of the Green House project in an Israeli nursing home: a comparative perspective through post-occupancy evaluation

Purpose With interviews and behavioral mapping, this study aims to explore the use of community spaces and shared residential rooms, as well as the implications that arise from some of the rooms facing the central community spaces, from the perspective of socio-spatial needs (including privacy, the sense of control and the sense of home and community). Design/methodology/approach This study analyzes and contrasts nursing home residents’ responses to the architectural design of two wards in a nursing home in Israel, one of which was partially remodeled based on the Green House Project, a model that aims to improve overall well-being through specific architectural design principles. Findings Among the residents, a sense of loss of control and being institutionalized may be linked to having to share rooms. A sense of autonomy gained by engaging in daily activities—such as washing clothes by hand and hanging them on a private balcony—was one of the highlights of the study, indicating how simple architectural decisions can enhance residents’ well-being. Observations of shared spaces suggest that residents did not use the large dining tables available to them; defined activity spaces for small groups may better match the current use. Originality/value As the first (and partial) implementation of the Green House Project in Israel, this case study provides a unique opportunity to examine the perceptions of residents who have transitioned from traditional ward settings to remodeled, home-like environments that are managed under the same administration.

Regulating AI in the Energy Sector: A Scoping Review of EU Laws, Challenges, and Global Perspectives

Using the PRISMA-ScR methodology, this scoping review systematically analyzes how EU laws and regulations influence the development, adoption, and deployment of AI-driven digital solutions in energy generation, transmission, distribution, consumption, and markets. It identifies key regulatory barriers such as stringent risk assessments, cybersecurity obligations, and data access restrictions, along with enablers like regulatory sandboxes and harmonized compliance frameworks. Legal uncertainties, including AI liability and market manipulation risks, are also examined. To provide a comparative perspective, the EU regulatory approach is contrasted with AI governance models in the United States and China, highlighting global best practices and alignment challenges. The findings indicate that while the EU’s risk-based approach to AI governance provides a robust legal foundation, cross-regulatory complexity and sector-specific ambiguities necessitate further refinement. This paper proposes key recommendations, including the integration of AI-specific energy sector guidelines, acceleration of standardization efforts, promotion of privacy-preserving AI methods, and enhancement of international cooperation on AI safety and cybersecurity. These measures will help strike a balance between fostering trustworthy AI innovation and ensuring regulatory clarity, enabling AI to accelerate the clean energy transition while maintaining security, transparency, and fairness in digital energy systems.

Sociocultural Dynamics of Islamic Legal Reform Across Muslim-Majority Countries: A Comparative Perspective

Background: Islamic law exists in a fluid and contentious realm inside modern Muslim-majority states, where its application embodies both theological beliefs and sociopolitical frameworks, as well as cultural perceptions. Purpose: This study seeks to evaluate the sociological elements affecting the implementation of Islamic law in Indonesia, Brunei Darussalam, and Saudi Arabia, emphasizing the roles of legal pluralism, state ideology, and religious authority in its enforcement Methods: The study employs a qualitative-comparative methodology, utilizing document analysis and secondary data review to examine the historical evolution, legal frameworks, and sociocultural contexts that support Islamic law in the three nations Results: The findings indicate that Brunei and Saudi Arabia implement Islamic law inside monarchical and theocratic structures, but Indonesia reconciles Islamic principles within a pluralistic legal framework shaped by democracy, adat, and secular constitutionalism Implication: This article theoretically enhances Islamic legal scholarship by contextualizing Islamic law within sociological and reception-focused frameworks, demonstrating that its legitimacy arises from intricate interactions among tradition, state, and society. The research provides insights for policymakers to formulate context-specific legal reforms that take into account normative Islamic ideals and varied sociocultural situations. Originality: Sociological perspective and cross-regional analysis, which transforms the discussion of Islamic law from strict doctrinarism to fluid social practice within the worldwide Muslim community

Muhammadiyah's Dilemma in Assisting the Rohingya Humanitarian Crisis in Myanmar

This study analyzes the strategies employed by Muhammadiyah in addressing the humanitarian crisis affecting the Rohingya ethnic group in Myanmar, along with its positioning within international policy frameworks. A qualitative method was used, incorporating in-depth interviews with the chairman and vice chairman of the Muhammadiyah Disaster Management Center (MDMC), who served as key actors in aid distribution in Myanmar, along with three other representatives from Muhammadiyah’s leadership. Secondary data, including academic journals, news articles, online sources, and literature reviews, were also utilized to support the analysis. The findings reveal that Muhammadiyah faces various social, political, and cultural challenges in Myanmar, including local resistance, the politicization of aid, and language barriers. Unlike state-led humanitarian interventions, Muhammadiyah operates under regional diplomatic constraints. These conditions require adaptive negotiation strategies with both governmental and non-governmental stakeholders. This study highlights the critical role of faith-based organizations in humanitarian diplomacy and offers a comparative perspective on Muhammadiyah’s position alongside international actors such as UNHCR and ICRC. It emphasizes the need for cross-cultural communication training, integration with ASEAN’s humanitarian frameworks, and stronger institutional partnerships to improve the sustainability of humanitarian missions. Academically, this research contributes to the discourse on humanitarian diplomacy by exploring the intersection of religious-based humanitarianism and international political dynamics. Practically, it provides policy recommendations to enhance aid effectiveness in conflict-affected areas.

Early parliamentary dissolutions and judicial review: lessons from comparative cases

In this article, I explore some implications of judicial challenges to early dissolutions of national parliaments from a comparative perspective. I assess two cases where the constitutionality of the dissolution was upheld (Germany 1983 and 2005) and four where it was not (Czechia 2009, Nepal February 2021 and July 2021 and Pakistan 2022). The evidence suggests that judicial intervention in parliamentary dissolution disputes is often inferred rather than explicitly codified in legal statutes, underscoring the profound impact unwritten constitutional norms and democratic tradition can have on the political process. Predictably, judicial scrutiny of governmental actions enables courts to oversee and, when necessary, rectify breaches of constitutional limits and instances of executive overreach. The Nepalese and Pakistani cases further suggest that the judiciary can play an active role in safeguarding the cardinal principle of parliamentarism, dictating that the legislature must be able to subject governments to the test of confidence when required or if it so desires. A review of the history of judicial intervention in earlier cases of assembly dismissals in Pakistan, however, highlights how this process is not always consistent and unbiased. Gaining a deeper understanding of these interactions is important, given their highly consequential nature, as well as timely, given the increasing reliance on the judicial branch for the adjudication of disputes related to parliamentary dissolution in recent years.

Finite and non-finite complementation of belief predicates in European and Brazilian Portuguese – qualitative and quantitative tendencies and contrasts

This paper investigates the two main belief (or doxastic) verbs acreditar and crer in European and Brazilian Portuguese. The focus of the study is on the selection patterns of these two verbs, taking into account semantic as well as syntactic aspects. Studying the selectional peculiarities of finite and non-finite structures in both varieties from a qualitative and quantitative perspective sheds light on a modal domain that is prone to a high degree of variation, both on an intra-linguistic and an inter-linguistic level, and therefore reflects micro-typological variation in the Portuguese language and in Romance as a whole. In particular, we intend to verify whether the selection of finite and non-finite inflected complements may constitute a case of intra-linguistic differentiation between these two major varieties, i.e. a dynamic that points to language evolution and change in contemporary Portuguese. Our analysis is based on Davies’ Web/Dialects sub-corpus, which enables a search for selection patterns determined by different person-marked matrix forms, namely acredito/acredita and creio/crê. The comparative study shows that there are clear quantitative differences in the selection of complement clause patterns with respect to both finite and non-finite, particularly inflected, structures. Of particular interest are the peculiarities and contrasts in mood alternations from a comparative perspective, as they reflect different dynamics of evolution within the contemporary language system. This specific part of the study is completed by a regression analysis of the quantitative data on mood alternations, assessing the statistical significance of crucial predictive factors. The final section summarizes the main findings of the study.

Multilevel Neuroimaging Insights into ECT Mechanisms in Clozapine-Refractory Schizophrenia: A Comparative Perspective with Depression

Multilevel Neuroimaging Insights into ECT Mechanisms in Clozapine-Refractory Schizophrenia: A Comparative Perspective with Depression

Understanding play from neurobiological, evolutionary, and comparative perspectives.

Understanding play from neurobiological, evolutionary, and comparative perspectives.

Women as Adjectives: A Comparative Study of Mrs. Warren’s Profession and Ashad Ka Ek Din

This paper attempts to show the losing metamorphosis of female identity into a tag of social roles and labels, turning women into “adjectives” in George Bernard Shaw’s Mrs Warren’s Profession and Mohan Rakesh’s Ashad Ka Ek Din. The study explores the representation of the systematizing oppression and objectification of women, situating both texts in distinctly related cultures and historical frames from a comparative perspective. The protagonists—Mrs. Warren and Vivie in the context of Victorian English life, and Mallika in ancient yet modernistically interpreted India—are early practitioners, who, like the protagonists of both novels, work within a male-dominated structures that inhibit their autonomy, upend their self- worth (as they know it to be) and generally subvert their sense of self.

A Comparative Perspective on the Future of Law in a Time of Artificial Intelligence

The article explores the impact of AI on legal systems globally. It highlights how technology, particularly AI, disrupts social order and power dynamics, necessitating legal adaptations. The document categorizes global AI regulatory responses into four types: no response, reliance on existing tech regulations, fragmented solutions, and unified approaches. The European Union (EU) has adopted a unified approach with the Artificial Intelligence Act (AIA), aiming to harmonize AI rules, address risks, and stimulate AI development. The United States employs a piecemeal approach with the National Artificial Intelligence Act of 2020 and various state laws and executive orders. Australia lacks specific AI legislation, but it has an AI Action Plan focusing on economic benefits and talent development. South Africa’s National AI Policy Framework emphasizes economic transformation and social equity. The African Union’s Continental AI Strategy aims for socio-economic transformation while addressing AI risks. Canada has a Voluntary Code of Conduct and a proposed Artificial Intelligence and Data Act (AIDA). The document critiques current AI regulations for incomplete definitions and a lack of focus on the broader societal purpose of AI. It stresses the need for regulations to consider ethical dimensions and societal impacts. The document concludes that AI regulation must balance innovation with social order, human dignity, and safety, emphasizing the urgent need to address AI’s energy and water consumption to prevent potential global instability.

Economic growth without carbon emission: Comparative perspectives on solar, wind, hydroelectric, nuclear, and geothermal energy

Economic growth without carbon emission: Comparative perspectives on solar, wind, hydroelectric, nuclear, and geothermal energy

Diachronicity: An issue shared between linguistics and literary studies

Both linguists and literary scholars deal with change over time. This special issue approaches the question of diachronic development from a comparative perspective, contrasting the ways in which analysis of changes observable in literary texts over the centuries is handled in the realm of literary studies and how linguists discuss language-specific (dis)continuities from one period to the other. For instance, as is well known, generic modifications and repurposing frequently play an important role in literary studies, while linguists often focus on form versus function analysis. These methodological preferences are not exclusive to the two fields, however. The essays in this issue demonstrate how very similar questions and often comparable methodologies are employed by linguists and literary scholars, especially by representatives of historical pragmatics and narratologists, who share methodological assumptions about form and function analysis.

Mother-Infant Face-to-Face Interactions Serve a Similar Function in Humans and Other Apes.

In humans, mothers and infants often engage in face-to-face interactions, which are often considered crucial for the social transmission of information and the typical social and cognitive development of infants. In this study, we used a comparative developmental perspective to provide an assessment of mother-infant face-to-face interactions in several great and small ape species and to better understand which aspects of face-to-face interactions are shared by humans with other species. We conducted longitudinal behavioral observations on 48 mother-infant pairs from five different genera (i.e., Hylobates: N = 9; Homo: N = 10; Nomascus: N = 6; Pan: N = 18; Symphalangus: N = 5), when infants were 1, 6, and 12 months old. Generalized linear mixed models revealed differences across ape genera and through development in the probability that mothers and infants engaged in face-to-face interactions during the first year of the offsprings' life. As predicted, these interactions were more likely when mothers and infants spent less time in physical contact, in communities usually characterized by more distal parenting styles (i.e., WEIRD humans), and when infants became older and thus motorically more independent. Overall, our findings suggest that face-to-face interactions were likely present in the common ancestor of humans and small apes, and likely serve a similar function across ape species.

The Phenomenon of Ostalgie in Czech and German Television Series

Ostalgia – a nostalgic longing for aspects of life in former socialist regimes – permeates various domains of social and cultural life, including fashion, consumer goods, music, and popular media. This study explores ostalgia on the cultural level, focusing in particular on contemporary television series. The theoretical framework draws on concepts of collective memory and the culture of remembrance, with special attention to the material dimension of memory. Ostalgic narratives frequently foreground everyday objects, evoking a sense of temporal dislocation wherein the past can only be accessed through selective remembrance. This phenomenon is discussed in relation to the notion of the 'memory of things', as formulated by Jan Assmann and further developed by Arjun Appadurai. Material artefacts from the socialist era serve as vessels of memory, enabling individuals to retrieve personal and collective pasts. The analysis centres on two Czech series – Vyprávěj (Tell Me About It) and Svět pod hlavou (World Under the Head) – and two German productions – Ku'damm (Kurfürstendamm) and Deutschland 83 (Germany 83) – offering a comparative perspective on how ostalgia is represented and mediated through televised storytelling in post-socialist contexts.