The Machinery of Legal Aid: A critical comparison, from a public law perspective, of the United Kingdom, the Republic of Ireland and the Nordic countries

Legal aidis one of the central mechanisms for achieving access to justice, but itsinternal workings are little understood. This study extends the range oflegal aid research by applying a public law perspective in considering thelegal basis for legal aid schemes and the internal mechanisms according towhich they operate. By using acomparative methodology, it highlights the variety and complexity of legal aidstructures in North-West Europe: the UK, the Republic of Ireland and the Nordic countries.

Taking keyaspects of legal aid systems in turn, the research examines decision-makingstructures, scope and merits criteria, both for civil legal aid and forcriminal legal aid and public defender schemes, across nine jurisdictions.Detailed comparison is made between the different schemes, which are evaluatedagainst each other and against the external benchmark of international humanrights obligations. The study enhances an understanding of how legal aidworks, how well it works and how it could be improved, and concludes with asuggested framework for further research.