THE ACTIVE ROLE OF THE COURT ACCORDING TO ADMINISTRATIVE LEGISLATION IN KAZAKHSTAN AND GERMANY. COMPARATIVE ANALYSIS

Studies show that the courts in Kazakhstan and Germany play an active role in administrative law, actively participating in the investigation of cases. In Kazakhstan, courts can collect evidence and express preliminary opinions, according to the administrative and procedure code. In Germany, the courts follow the inquisitorial model, where judges are actively investigating facts, which enhances their role in administrative disputes. A comparative analysis shows similarities in an active role, but differences in legal traditions and procedures.