Counterterrorism Law and Policy in the United Kingdom, Canada, and Australia: A Comparative Perspective

Abstract

This article looks at the similarities and differences in British, Canadian, and Australian counterterrorism laws and policies. Canada and Australia are contrasted with the United Kingdom because their respective approaches to counterterrorism are based on the British approach, and yet have evolved to take into account differences in the nature and scope of the threat and the differing styles of governance in place in Canada and Australia. The article looks at each country in the context of: counterterrorism laws; detention and disruption practices; investigatory approaches; intelligence and law enforcement institutions; and the treatment of foreign fighters. The article then draws some conclusions regarding the evolution and divergence of counterterrorism law and policy in these countries and posits a question for future research.