This paper provides an in-depth examination of the concept of separation of powers in India, the UK, and the US. It explores the historical development and evolution of the separation of powers doctrine in these countries, considering its theoretical foundations and practical implications. The paper conducts a comparative analysis of the legislative, executive, and judicial powers in India, the UK, and the US, highlighting similarities and differences in their respective systems. Special attention is given to the role of the judiciary in safeguarding the separation of powers and ensuring accountability. The constitutional provisions and mechanisms that establish and protect the separation of powers are explored, with a particular focus on checks and balances. The paper also delves into the challenges and controversies surrounding the separation of powers in these three countries, addressing potential threats and shortcomings. Finally, drawing insights from the comparative study, the paper offers valuable lessons and implications for enhancing the separation of powers in India, with relevance to other jurisdictions. By examining these aspects, this paper aims to deepen our understanding of the separation of powers as a crucial component of democratic governance and shed light on its practical application in different contexts.
Abirami et al. (Tue,) studied this question.