ABSTRACT

The Ombudsman institution, which originated in Scandinavia, is one of the most significant mechanisms for administrative accountability in today’s world. It continues to influence governance models worldwide. Sweden and Norway are the pioneer jurisdictions in this field of administration. They offer mature yet distinct models of the Ombudsman institution. Both countries are distinctively shaped by their political culture and administrative frameworks.

Despite initially sharing a common monarch, Sweden and Norway differ in their Ombudsman institutions. This article compares the Ombudsman institutions in Sweden and Norway. The study is conducted from the standpoint of their creation, historical development, appointment, removal, jurisdiction, exemptions from jurisdiction, unique powers, functions, and overall political efficacy in guaranteeing the institution’s sanctity and shielding citizens from maladministration by delivering justice.

This article aims to fill the gap of research on the effectiveness of Ombudsman models in these two countries by comparing them. The study employs analytical, comparative, and critical research methods, as well as a doctrinal research methodology. It relies on constitutional provisions, historical accounts, statutory frameworks, official reports and secondary sources of data to assess how each jurisdiction has operationalised the role of Ombudsman. The research is limited to the Parliamentary ombudsman in both countries and contains only the unique and special features native to each country.

Keywords: Ombudsman, Sweden, Norway, Public Administration.

INTRODUCTION

The institution of the ombudsman is an essential component of modern democratic governance. It has been adopted by many countries worldwide. It has evolved with different connotations in different countries. It is an extremely important part of protecting citizens’ rights and holding public authorities accountable for their actions.

In simple words, the term “ombudsman” comes from the Swedish word “ombud” which most commonly refers to a person who acts as a spokesman or representative for another person or group of people in the Swedish language. Garner defines ombudsman as “an officer of parliament, having as his primary function, the duty of acting as an agent for parliament, for the purpose of safeguarding the citizen against abuse or misuse of administrative power by the executive”[1]. The Ombudsman is an independent office created to investigate and redress complaints against public authorities and institutions. The need for an Ombudsman arises from the potential abuse of power by government officials and institutions, which can lead to violations of human rights, corruption, and other forms of maladministration.[2] As an independent oversight body, the Ombudsman plays a crucial role in ensuring that public officials are held accountable for their actions and that citizens’ rights are protected.[3]

The design and functionality of the institution of the ombudsman may differ from one country to another, reflecting the different societal and political cultures of those countries. The institution of the ombudsman, which encourages transparency, fairness, and accountability, has been established as a cornerstone of good governance in the Scandinavian countries.

This article focuses on the two basic models followed in the Scandinavian countries, called the disciplinary model and the quasi-administrative court model or the reformative model. Both models are discussed with respect to two distinct countries Sweden and Norway which follow these two different models, in detail in this article.

[1] Yash Dhawan and Vidhi Marwaha, ‘Position of Ombudsman in India’ (2020) 3(2) IJLMH <https://www.ijlmh.com/wp-content/uploads/2020/05/Position-of-ombudsman-in-India-2.pdf> accessed 17 December 2025.

[2]United Nations Development Programme, ‘The Ombudsman: Good Governance and the Rule of Law’ <https://www.undp.org/content/undp/en/home/librarypage/democratic-governance/the-ombudsman–good-governance-and-the-rule-of-law.html>accessed 17 December 2025.

[3] ibid.