COMPARATIVE LEGAL ANALYSIS OF SOME NORMS OF THE RIGHT TO HEALTH

Abstract

This article presents a comparative legal analysis of certain norms regarding the right to health, using examples from Western European, North American, and Commonwealth of Independent States countries. The right to health is examined as a fundamental social human right, recognized in various international human rights documents. The article details positive actions taken by states to ensure access to basic types of medical services, which encompass the main components of the right to health. The work identifies insufficient regulation of criminal liability in the field of medical law as one of the barriers to accessing quality healthcare. Accordingly, this aspect is studied through the experiences of countries such as France, Austria, Poland, the USA, Kyrgyzstan, Kazakhstan, and Uzbekistan. The approaches of some CIS countries are also considered.