Global Responses to Terrorism: A Comparative Study of Counter-Terrorism Legislation

Vishal Anand

Comparative Law, Counter-Terrorism, Human Rights, Legislation, National Security.

This article presents a comparative analysis of counter-terrorism legislation in the post-9/11 era, examining the frameworks of the United States, United Kingdom, France, and India. It argues that while the global response to terrorism, heavily influenced by UN Security Council Resolution 1373, has led to a convergence of legislative trends favouring pre-emption, surveillance, and the expansion of state power, significant divergences exist, shaped by national legal traditions, historical contexts, and specific threat perceptions. The study investigates key legislative instruments such as the USA PATRIOT Act, the UK’s Terrorism Acts, France’s state of emergency laws, and India’s Unlawful Activities (Prevention) Act. It analyses the thematic trends across these jurisdictions, including the broadening definitions of terrorism, the erosion of privacy through mass surveillance, and the weakening of due process rights. The article concludes that this global legislative hyperactivity, while aiming to enhance security, has created a profound and persistent tension with fundamental human rights and civil liberties. It suggests that long-term effectiveness in countering terrorism requires a recalibration, moving beyond purely securitized responses to embrace a holistic approach that upholds the rule of law and addresses the root causes of political violence.

Volume 10 Issue 9, September-2025

Pages : a72-a82