Comparative Legal Analysis of Models of Mass Media Legal Regulation

Modern constitutional and legal doctrine often uses the legal diffusion of ideas, models and concepts used in legal systems that were formed in fundamentally different historical and socio‑cultural conditions. This approach does not take into account the uniqueness of national legal traditions and the specifics of the relationship between the state and society in a particular country, which leads to a theoretical incompleteness of typification. The purpose of the study is to conduct a comprehensive comparative legal analysis of media regulation models in order to identify the limits of the applicability of typification and substantiate the need to supplement it. To achieve this goal, the following tasks were solved: the essential characteristics of the models were analyzed; the methodological limitations of their application to other types of legal systems were identified; based on the analysis of legislation, additional models are formulated and described — party‑corporatist and paternalistic (partnership), characteristic of the legal systems of individual states of East Asia and the Russian Federation, respectively. The methodological basis of the research was a combination of general scientific and private scientific methods. The comparative legal method was used as the main tool, which made it possible to identify different approaches to the legal regulation of mass media in countries with different legal systems. The formal legal method was also used to analyze normative legal acts and the historical legal method to study the genesis and evolution of legal institutions. Conclusion: the typification of Western models of media regulation, despite its scientific significance, is not universal. The author suggests supplementing the typification with models, in particular, party‑corporatist and paternalistic (partnership).