Irretrievable Breakdown of Marriage: A Comparative Doctrinal Study of Institutional Ethics Review Frameworks in the United Kingdom of Great Britain and Northern Ireland, Canada, the Commonwealth of Australia, and the Republic of India

Abstract

This study undertakes a doctrinal and comparative examination of institutional ethics review mechanisms governing research involving human participants, with particular reference to the United Kingdom, Canada, and Australia, and their relevance for India. The research proceeds on the premise that contemporary Institutional Review Boards and their functional equivalents have evolved into legally significant bodies responsible for safeguarding participant autonomy, dignity, welfare, and informational privacy. Relying exclusively on secondary sources, including statutory frameworks, regulatory guidance, and leading judicial pronouncements, the study analyses the substantive criteria, procedural architecture, approval timelines, and participant protections embedded within the selected jurisdictions. The findings reveal substantial normative convergence across the three foreign systems, particularly in relation to scientific validity, proportional risk assessment, meaningful informed consent, equitable participant selection, and confidentiality safeguards. However, important operational distinctions persist. The United Kingdom demonstrates the advantages of centralised digital integration and defined decision timelines; Canada reflects a principled yet decentralised institutional model; and Australia offers a hybrid framework combining national guidance with registered committee oversight. Across jurisdictions, proportionate review pathways and transparency mechanisms emerge as key determinants of regulatory efficiency and public trust. When evaluated against this comparative baseline, India’s ethics governance framework appears normatively robust but institutionally uneven. While the ICMR National Ethical Guidelines and the New Drugs and Clinical Trials Rules have strengthened the regulatory foundation, challenges remain in the areas of procedural uniformity, committee capacity, data governance assessment, and public transparency. The study concludes that India would benefit from calibrated institutional reforms, particularly the development of an interoperable national ethics submission platform, strengthened accreditation and training of ethics committees, culturally responsive consent processes, and tighter integration of privacy review within ethical scrutiny. The research ultimately affirms that effective ethics oversight enhances both participant protection and the legitimacy of scientific enterprise, and that India stands at a critical juncture in translating normative commitment into operational coherence.