This article provides a comprehensive analysis of the foreign experience in the formation and functioning of administrative court systems. It examines the main models of administrative justice, including the French, German, Anglo-Saxon, and mixed variants used in certain countries of Central and Eastern Europe. Particular attention is given to the possibility of applying foreign approaches in the process of improving the Ukrainian system of administrative justice. Promising directions for reforming administrative courts in Ukraine are identified, taking into account international standards, particularly in the areas of enhancing judicial independence, digitalization of procedures, simplifying case review processes, and introducing effective pre-trial mechanisms. The conclusion is made on the advisability of selective implementation of foreign experience with mandatory consideration of national legal and social conditions. A comparative analysis of different administrative justice models helps avoid common mistakes inherent in individual legal systems. For example, excessive bureaucratization or insufficient institutional independence can negatively affect the effectiveness of administrative courts. Studying such aspects helps Ukraine avoid such problems when improving its model consciously. At the same time, it helps to borrow effective mechanisms that can be adapted to domestic conditions to improve the quality of administrative justice. In particular, this includes improving the structure of courts, introducing the latest technologies, strengthening guarantees of judicial independence, and developing pre-trial dispute resolution procedures. Therefore, it is relevant to study the main models of administrative justice abroad, to identify their strengths and weaknesses, as well as to determine which elements of foreign experience can be adapted to Ukrainian realities in order to improve the efficiency of administrative courts. Keywords: administrative justice, judiciary, administrative court system, models of administrative courts, foreign experience.
Khomyshyn et al. (Sun,) studied this question.