THIS SECTION EXAMINES COMPARATIVE LEGAL ARRANGEMENTTS, INSTITUTIONAL frameworks and procedures of the three regional human rights mechanisms that now exist, to learn how these mechanisms have been functioning. Have they been functioning effectively? What are the institutional characteristics and strengths and limitations of each regional human rights regime? 1 What has been the role of NGOs in these three regimes? How relevant is the experience of these three regimes to the human rights regime in East Asia?
Presently there are three regional human rights implementation mechanisms in operation, namely, the European, Inter-American and African systems. The three regional regimes differ in the breadth and depth of the rights they recognize. Leary asserts that the most effective human rights implementation systems are regional arrangements because governments are more likely to agree to regional machinery for supervision where cultural, legal and intellectual traditions are similar. 2 Cultural relativists 3 argue that the content of rights must be compatible with (universalists argue that human rights must be applied with sensitivity to) a society's cultural, political, and social circumstances in order to be accepted and effectively realized.
The European human rights system, the most developed system for the regional protection of human rights, has its legal origins in two treaties: The European Convention on Human Rights of 1950 4 and the European