The Tension Between Private Ownership and Public Interest in the Protection of Cultural Heritage: A Comparative Study Between France and Jordan

Cultural heritage is important in defining national identity, legal and political priorities. However, its preservation exposes tensions between public interest and private rights. This paper presents a comparative analysis of two systems: France, a European Union member with a resilient system, and Jordan, with a centralised heritage system. Using a comparative analytical approach and case studies, this research examines the ownership rules, restrictions, and compensation, with a particular focus on the contradiction between public and private ownership. Findings highlight that the French model adopts a disciplined framework based on public-private partnerships, promoting private ownership of cultural heritage through tax incentives and property restitution. In contrast, Jordan adopts a state-centric approach characterised by limited compensation, ambiguous mechanisms, and community participation. This research contributes to bridging the gap in comparative heritage studies. The paper proposes that Jordan adopt reforms, including fair compensation and participatory governance inspired by the French experience in sustainable heritage.