This paper examines the disconnect between international refugee protection norms and their domestic implementation through a comparative analysis of India, Türkiye, and the European Union. While international law—particularly the 1951 Refugee Convention, international human rights treaties, and the principle of non-refoulement—establishes strong protective standards, state practice often remains fragmented and inconsistent.Focusing on India’s non-codified, discretion-based framework, the study contrasts it with Türkiye’s statutory Temporary Protection regime and the European Union’s Common European Asylum System, highlighting how codified legal structures influence refugee status determination, access to rights, and compliance with customary international law. Special attention is given to judicial responses, institutional accountability, and the treatment of vulnerable groups, including Palestinian refugees.The paper argues that comprehensive legislative frameworks significantly enhance predictability, procedural fairness, and refugee protection outcomes, and concludes with recommendations for rights-based reform to bridge the gap between international obligations and domestic practice.
AAYAT RAFIQ (2026) studied this question.