Introduction

Participatory democracy asserts that citizens’ political participation is one of the most vital components of the political system. It also asserts that there are numerous avenues for participation in the making of political decisions at the national, state, and local levels. Its main characteristics are that all participants in a political dialogue must present their points of view, that any interested citizen may access the authorities’ arguments, that the decisions reached during the dialogue between the authorities and the citizens are legally binding, and that the dialogue is ongoing (Barber, 2014). It is precisely on this basis that the principles governing the use of dialogue-based forms of political participation can be translated into political time. Maintaining democracy necessitates ongoing effort on the part of all parties involved in the political process. Its mechanisms and procedures do not occur spontaneously. Instead, they are the result of deliberate actions by civil society members seeking to foster a culture of political participation (Pateman, 2012).

Democratic discussions have historically emphasised the significance of representative and participatory governance, analysing whether or not citizens prefer to give their voice to elected officials or to have a more direct influence on current political issues. Regardless of the difficulties of representation and participation in practice, scholars generally assume that citizens desire more participation opportunities (Font et al., 2015). This suggests that people who are critical of political institutions and believe that current mechanisms are insufficient to address current issues are more likely to support changes that aim to expand democratic freedoms and the free expression of the will of the people, or grassroots democracy (GD). Such attitudes imply a lack of satisfaction with the way democracy, in general, and democratic institutions, specifically, operate (Kaufman and Dilla Alfonso, 1997). Consequently, there is a growing desire for political transformation through citizen participation in decision-making. In light of this, it is not surprising that dissatisfaction with representative democracy is increasingly seen as the primary reason for citizens’ preference for direct democracy. Additional research has supported this theory and discovered a link between political dissatisfaction and a preference for direct democratic decision-making (Hibbing, 2001). However, results from other studies about the connection between political dissatisfaction and preference for direct democratic decision-making are less certain and more ambiguous. People who prefer voting in referendums frequently have a strong commitment to democracy but little faith in representative democracy’s institutions (Gherghina and Geissel, 2019). Other studies reach the opposite conclusion. A comparative study of several countries, for instance, revealed that citizens who trust the institutions of representative democracy support direct democratic decision-making more strongly than those who do not (Bowler et al., 2017). Recent years have seen a rise in scholarly interest in the preference for direct democracy among so-called populist political parties and their supporters, particularly in the context of political dissatisfaction. However, this trend is not commonplace. Additionally, voter dissatisfaction with domestic and foreign policy issues in some countries, especially Australia and New Zealand, is unrelated to their wishes to support grassroots methods of expressing their will and increase civic engagement in politics (Gherghina and Geissel, 2019).

Many authors acknowledge the difficulty of establishing a systemic dialogue between the government and the people. Researchers are becoming more and more interested in such dialogue aspects, such as the analysis of political participation methods best suited to the openness of power strategies and the implementation of political governance based on public policy principles, or grassroots governance (Barber, 2014). In contemporary scholarly usage, the term “grassroots” generally refers to groups of citizens at the regional, and local level within the state’s jurisdiction, who are typically powerless and unaffiliated politically. The leadership level is the opposite of the grassroots level. In terms of political participation, having grassroots support means having support from the people rather than the party or political elite. A mass movement or campaign is a movement that gathers people at the territorial community level to engage in debate and political action (Political Dictionary, 2022).

The question of whether grassroots democracy improves local self-governance is not unequivocally answered in theory. While accepting the fact that democracy certainly empowers citizens at the level of the administrative-territorial units where they live and increases the accountability of local government, at the same time it must be understood that the decentralised nature of GD gives local elites additional opportunities to influence local politics in their interests (Wang and Yang, 2010).

As can be seen, the concept of GG is inseparable from the concept of GD and is derived from it. Quite a lot of work is devoted to the concept of GD, and the concept itself has become firmly established in research use in the framework of interdisciplinary research. However, at present it is difficult to identify the fundamental theoretical developments that explain the legal essence of the GG, and the features of its institutionalisation. Most of the works are in the nature of political studies only occasionally directly intersecting with jurisprudence and public administration (Hall, 2011; Palanithurai, 2005; Turok and Scheba, 2020). In this paper, an attempt is made to compensate for this gap and present a legal view of the problem. At the same time, it is obvious that it is not possible to consider the issue in isolation from related fields of knowledge, including political science since GD directly affects the issues of the political regime of the state.

Despite significant theoretical contributions to grassroots democracy research, there is a clear theoretical gap in grassroots governance research. Examples and practices are provided, as well as differences between direct democracy and grassroots democracy, grassroots governance, and the relationship between these concepts. Recent theoretical descriptions of the aforementioned issues suggest that grassroots democracy can broaden the toolkit for public participation, creating a range of potential benefits for larger-scale social development issues. It is important to discuss how these mechanisms fit into the larger picture of grassroots democracy to evaluate grassroots governance mechanisms accurately. This study investigates the experiences of various nations in putting grassroots democracy and grassroots governance mechanisms into practice. It aims to assess the opportunities and prospects for decentralisation and adaptation of individual self-governance mechanisms in the context of community social development.

Theoretical context and review of sources

Contemporary research on specific GG elements in the context of social policy has concentrated on topics such as:

- governance mechanisms and basic practices of grassroots social governance and its institutionalisation in China, the USA, Great Britain, Japan, and Singapore (Cai, 2022),

- citizen preferences in political decision-making processes (Font et al., 2015),

- an experience of grassroots governance in the Philippines (Turok and Scheba, 2020),

- municipal consolidation and elimination of municipal governance at the grassroots level (Buikin, 2019),

- the role of primary elections within grassroots governance (Seddone and Sandri, 2021), and

- the origins of grassroots democracy (Singh, 2020).

The terms GD, and GG are now increasingly used in interdisciplinary research at the intersection of political and legal sciences. The first is considered a form of self-organisation of the population, a subspecies of a democratic political regime, the second—as a way to exercise democratic rights. It is argued that grassroots groups can develop new solutions to existing problems and use both local governments and citizens to do this. In both rich and resource-poor regions and countries, organisations at the grassroots level can develop an alternative voice of the local population, defending both their rights and representing the most vulnerable strata of the population (Redondo-Sama, 2020).

In the science of the post-Soviet countries, the issues of GD, GG have been limited studied. A separate post-Soviet study links GD exclusively to party activity, noting that grassroots democracy is associated with the widening the autonomy at grassroots party levels (Shulenina, 2007; Tyutin, 2019).

The GD concept has been actively used in China in recent years, not only at the level of research but also at the level of political documents. As can be noted, in Chinese political and legal thought, the view is being strengthened that grassroots governance, based on the idea of grassroots democracy, is an institution and a level of power. At the same time, local civil communities should become a school of civic activism and help build social ties. The first studies on GD, GG in the PRC were mostly devoted to such issues as elections in Chinese villagers’ committees (Jakobson, 1999; Kelliher, 1997), the role of foreign non-governmental organisations in the development and promotion of rural elections in China (Grove, 2000). Over time, interest in the study of GD mechanisms has only intensified and the scope of the study has expanded. Recognising the important theoretical contribution to grassroots democracy research, it should be noted that at present there is a certain theoretical gap in research on grassroots governance, description of examples and practices, differences between direct democracy and grassroots democracy, grassroots governance and the relationship between these concepts.

Modern works are mainly of a political nature or are considered from the point of view of the science of public administration. However, little attention has been devoted to the issues of legal understanding of the concepts of GG, GD, and legal institutionalisation in these studies. It was rather complicated to find any comparative legal studies dedicated to GG and GD. In addition, it is worth noting that a number of theoretical developments considered previously (in particular, issues related to the participation of women in the GG (Hazarika et al., 2014; Kaufman and Grace, 2011), issues of good governance at the grassroots (Palanithurai, 2005; Panday and Rabbani, 2011) are almost not presented for today.

Methods

Using the method of political and legal analysis this paper examines the origins, characteristics of legal regulation and administrative and managerial approaches to grassroots management issues from the perspective of social development prospects. The method employed seeks to examine the political initiatives and actions of the authorities in light of certain legal relationships and social challenges. Through an analytical lens, the experiences of three nations—Switzerland, the Philippines, and China—exemplifying distinct ways of understanding the term “grassroots governance” are presented.

The political and legal component of this study involves the consideration of political and legal measures related to the legal implementation of the GG concept in the framework of achieving the goals of social development. Representing a qualitative method, the method of political and legal analysis is aimed at studying the legal regulation and actions of authorities in the context of considering certain legal relations and challenges. At the same time, the key component of the method is the study of legislative regulation in conjunction with the political priorities of the state and from the perspective of international practices. Since part of the work covers the theoretical aspects of the concepts of GD and GG, there is also used the content analysis method. The latter allows us to analyse theoretical approaches related to the subject of research. As a result of the synthesis of theory and political and legal regulation, it is supposed to determine the institutional status of GG in the system of law and assess the current role of the GG in the framework of legal regulation in the countries under consideration.

The purpose of the study necessitated consulting the experience of nations where mechanisms of direct public participation in the discussion and adoption of political and administrative decisions have been in place for a considerable length of time. As the most obvious example of such countries, Switzerland is of interest; it is a state that is nearly unique in its representation of direct democracy. As opposed to Switzerland, the examples of the Philippines and China are instructive in terms of the fundamental differences in grassroots self-organisation approaches, the formation of a particular type of grassroots organisation in each nation, and the interactions and integration of these organisations with local authorities.

The legal instruments from Switzerland (Federal Act on Political Rights, Swiss Federal Constitution), the Philippines (the Local Government Code of the Philippines 1991 and the Urban Development and Housing Act 1992), and a Chinese policy document (Opinion of the Central Committee of the Communist Party of China and the State Council on Strengthening Grassroots Modernisation of Administration and Management Capacity, 28 April 2021, addressing local government empowerment) serve as the documentary basis for this study.

Results and discussion

The debate between representative and participatory governance at different levels has been at the centre of the theory of democracy for a long time, pointing out the tensions between the two. To this day, the debate over whether citizens or elected representatives should play a central role in policymaking is largely rhetorical. On the one hand, the representative model has been the most common form of governance in Western democracies for at least the last century (Dalton et al., 2001). Other nations, particularly some socialist nations and nations with a traditional legal system, have since copied this model in some way seeking to adapt it to the present circumstances. It is understood that governance requires time, knowledge, and experience that cannot be expected from regular citizens due to the objective complexity and multifaceted nature of political and governance processes (Kaufman and Dilla Alfonso, 1997). History, especially the world order after World War II, has led to a kind of consensus among politicians, scholars, and civil societies that electoral democracy is perhaps the ideal political system for building civil society, the rule of law, and human rights, and that the democratic regime is the model political regime that sets the standard. From a political and philosophical standpoint, it is customary to assume that the state is best run by elected officials with little to no direct involvement from the general public (Font et al., 2015). Nevertheless, as public trust in political parties and other institutions has subsided over time, scholars and professionals have suggested several institutional mechanisms for direct citizen participation that would supplement representative processes and be connected to a perceived desire for public participation (Font et al., 2015).

Increasingly, contemporary research identifies the need for greater direct participation, with support for direct, immediate participation in discussion, policy, and management decisions at various levels (Anderson and Goodyear-Grant, 2010; Neblo et al., 2010). Overall, governmental and non-governmental organisations arranging initiatives aimed at boosting direct citizen participation have reacted favourably to such an initiative (John et al., 2009). There is, however, valid criticism of such efforts. In the United States, for instance, several studies indicate that citizens are equally dissatisfied with debates and compromises at the level of government actors, as well as distrustful of their fellow citizens and unwilling to participate in actions that could lead to conflict and disagreement (Font et al., 2015; Theiss-Morse, 2002). And although neither legal nor political science directly equates the concepts of “grassroots” and “direct democracy” with each other, it is obvious that from the point of view of the layman, these concepts almost mean the same thing—decision-making is carried out at the lowest social level. Although the difference may not be obvious at first glance, in the end, it is not described in political science and other social sciences. For jurisprudence, where the principle of “legal certainty” exists, such an outcome is unacceptable, since an indefinite concept cannot be institutionalised and regulated by law.

The debate over the definition of GD (and GG as a derivative term) can be “enhanced” by public perception and “arbitrary” interpretation of these terms, which from purely scientific sources have come into common use. For example, the journalistic materials sometimes correspond to the GD with the so-called processes of spontaneous mass participation through networks of organised civil society (civil society organisations), online initiatives, and civil self-organisation around anti-corruption protest movements or around specific political issues (Youngs, 2021). Being a manifestation of a spontaneously organised democratic initiative, they are opposed to the organised actions of political forces and consequently may fall under the scope of the GD. On the other hand, there is an example of a referendum on BREXIT, where the right to determine an important political decision was granted at the broadest level in the frames of an organised initiative coming from the authorities. In both cases, the right to make decisions is at the lowest social level, while in the first case, we are talking about association for the purpose of implementing political initiatives (political power), and in the second case we are talking about participation in the implementation of decisions of higher subjects of state power (state power, authorities). In other words, in the case of a referendum on BREXIT, citizens participate in the implementation of state policy, but the initial formal initiative does not belong to them. One way or another, it is obvious that the list of those concepts, and actions that could be presented as elements of the GD concept is not exhaustive today. However, the points of intersection with direct democracy are obvious.

Discussions about direct democratic institutions touch on several issues. The democratic ideals of popular sovereignty, political equality, and all proponents of participatory democracy who support the notion that all citizens should have the right to not only elect representatives but also to vote on political issues in referendums are the normative justifications for direct democracy that are the most persuasive (Kaufman and Dilla Alfonso, 1997). Switzerland is perhaps the most telling example of the use of direct democracy instruments at the local community level. However, the institutions of direct democracy that characterise this country cannot be viewed as a viable alternative to representative democracy; rather, they can be viewed as a supplement or counterbalance to democratic systems with fundamentally representative characteristics. At the same time, institutional differences and competition between representative and direct democracy processes are central to the debate over whether direct democracy undermines representative democracy or enriches it (Benazir, 2021).

In general, representative democracy is regarded as superior because general elections provide citizens with a diverse selection of candidates and political platforms, which must demonstrate their competence in a democratic contest. Governments and parliaments, according to popular belief, have a greater capacity to make informed decisions, including expert assessments, because representatives can be held accountable for their decisions (Benazir, 2021).

Simultaneously, a liberal approach to governance highlights the significant shift from the state to the private sector. The role of the executive branch now increasingly resembles public–private partnerships, with formal and informal networks involving state and non-state institutions, organisations, and agencies playing an increasing role. Scholars are increasingly debating the inevitable transformation of certain aspects of public administration, focusing on the phenomenon of so-called governance without government, which is being highlighted as a distinct trend. Based on this assumption, managerial powers do not have to return to the power vertical in the traditional sense. Such opinions are supported by the observation that horizontal interaction, negotiations, coordination of actions and plans, the growing importance of social networks, and other phenomena show how effective governance functions. Simultaneously, “governance without government” implies a conditional reliance on commercial, semi-commercial, and decentralised markets (He, 2003). This trend is inextricably linked to the idea of GG when analysing the potential for power function diversification. The latter should be regarded as a tool designed to aid in this process. At the same time, referring to the legal essence of the concept of GG, it should be noted that at the international legal level, this concept does not have a solid legal basis, in contrast to the concept of “Local Self-Government”, which, in essence, is very close in its semantic content, however, unlike the first, is widely enshrined both at the level of individual jurisdictions and in international acts, for example, in the European Charter of Local Self-GovernmentFootnote 1.

When considering grassroots governance, it is worthwhile to consider the experiences of countries that have long had mechanisms for direct public participation in political-governance discussions and decisions in place. Switzerland is the most prominent example of a country that fits this description. The political system in Switzerland is built on the principles and tools of direct (legislative initiative and referendums) and representative (political parties and the parliament) democracy. The most advanced system of direct democracy in the world is thought to exist in Switzerland. It is unique in that it has a history of more than 150 years, and it also leads in terms of the number of votes and referendums. Indeed, there have been over 600 over this period. When the cantons united to form a federal state in the mid-19th century, the modern tools of democratic participation in government first appeared in Switzerland. The people’s legislative initiative appeared at the end of the 19th century, marking the official start of direct democracy in the country (Turok and Scheba, 2020).

Parliamentary elections are held every 4 years by electing deputies. The deputies elect a Federal Council, i.e. a government consisting of seven equal members. These are the ones who are entrusted with the functions of state administration. Each of the seven members of the government represents one of the four leading political parties in Switzerland and each of them can serve as president for one year (Fossedal, 2018).

Direct democracy guarantees citizens’ right to participate directly in state governance. This form of government, along with federalism and a neutral policy, distinguishes Switzerland. The origins of direct democracy in the country date back to the beginning of the 19th century, when a constitutional plebiscite was first held. With the adoption of the first constitution, its text was changed several times, but the right of grassroots initiative was almost always present in it. For more than 100 years, in addition to the right to a constitutional or constituent referendum, the Swiss people have also had the right to a legislative referendum. It concerns ordinary (unconstitutional) laws. With the adoption of the 1999 Federal Constitution now in force in Switzerland, the list of issues subject to mandatory and optional referendums remained virtually unchanged, they were only more clearly stated. (Solomonova, 2020). Currently, the legal basis for the mechanisms for implementing direct democracy is the Federal Act on Political Rights and the Federal Constitution of SwitzerlandFootnote 2. Using popular legislative initiative, citizens can propose constitutional amendments and new bills or amendments to existing legislation through the people’s legislative initiative. To accomplish this, a specific number of signatures must be gathered within the legally mandated time frame, notarised, and submitted to the Federal Chancellery. If citizens have a complaint about a specific federal law passed by parliament within a hundred days, the decision can be put to a vote. The timing and procedure for gathering signatures for a referendum are set by law and are limited to three months (Rochat, 2022).

Direct democracy, especially as it is done in Switzerland, has some clear benefits. The involvement of citizens comes first and foremost. When each citizen is given a share of power, society is no longer apathetic to the political life of the state. People are expected to be interested in politics and to research and participate in political processes. Alongside this, a proportional allocation of responsibility is evident. The assumption is that direct democracy is essentially a thinker’s society, capable of comprehending decisions and fully comprehending their consequences. From a GG standpoint, one of the benefits of direct democracy in Switzerland is the reduction in bureaucratic procedures. The distribution of power allows for the formation of a system in which routine bureaucratic issues are not confined to a single service or official. As a result, there is no such thing as a bureaucratic hierarchy. E-governance mechanisms that have been developed also contribute to this (Gherghina and Geissel, 2019).

Undoubtedly, the state-building practices in Switzerland are of special interest in terms of investigating direct participation in grassroots political decision-making and the resulting grassroots governance initiatives. However, it is essential to recognise that the political order in Switzerland is largely the result of the country’s long history of direct democracy. In this regard, the question must be raised as to whether the characteristics of direct democracy (participatory democracy) are the exclusive domain of European nations and whether this experience can be termed grassroots governance, or whether grassroots governance can take on other forms and be applied in other historical–geographical contexts. At the moment, the answer appears to be in favour of the latter assertion. Scholars currently believe that grassroots democracy and grassroots governance may have different origins and exist in different historical and political contexts. In the context of this study, the experience of the Philippines, for example, is of particular interest. Local GG in the country is based on barangay, which is a unique Filipino way of self-organisation and self-government that has been gaining more focus in recent years. The term “barangay” now refers to the smallest administrative unit in the Philippines and the lowest level of government. Nonetheless, its existence dates back at least 500 years (Porio and Roque-Sarmiento, 2019). There are over 42,000 barangays with populations ranging from 500 to 5000 people. Each is made up of a small group of elected officials and a group of appointed officials who help them do their jobs. According to recent studies, barangays promote local democracy, faster service delivery, and community participation in civic affairs (Turok and Scheba, 2020).

Those who have studied the subject are generally in agreement that the peculiarities and structure of local government in the Philippines are not unique to the region. There are many different types of local government administrative units, such as street committees or other informal governance mechanisms, in many nations around the world. Barangays, on the other hand, have a different level of legitimacy and support from the government and more legal protections. This includes electing a new leader every 3 years and making sure the national government has enough money to pay for a variety of public goods and services and protect vulnerable groups from natural disasters, accidents caused by people, and other emergencies. These tasks are essential in areas that are rapidly urbanising and are exposed to a variety of risks and pressures. The Local Government Code of 1991 and the Urban Development and Housing Act of 1992 established reforms to empower local communities. These outlined the barangay status as a unique level of decentralised government meant to strengthen democracy and under-mine the dominance of traditional political families and other local elites. Despite some reservations, the majority of observers applauded the process’s devolution of power and resources from the government’s central office, encouragement of citizen engagement, and integration of local priorities into the delivery of essential services (Turok and Scheba, 2020).

When discussing the benefits of the barangay system, it should be noted that the formal powers and resources of barangays are significantly less than those of municipal and provincial heads of municipalities. They provide a variety of health, nutrition, and welfare services, as well as solid waste collection and disposal, day-to-day maintenance of local roads and water infrastructure, and basic recreational and information services. Depending on the size of the barangay, the number of staff employed to provide these services ranges from 20 to 100. Instead of a salary, many of these workers receive an allowance. This implies a commitment to community service rather than monetary compensation (Turok and Scheba, 2020).

Alongside this, the existing system has several obvious shortcomings. First, despite legal guarantees of impartiality, the organisation remains susceptible to manipulation and bias (Porio, 2012). Some political forces and local elites have succeeded in introducing barangay representatives into elected bodies and integrating them into local power structures in some locales. There has been some influence on barangay activities by city officials and locality heads, as well as attempts to align barangay work with their own plans and agendas. They can allocate services and additional resources in ways that make it difficult for barangays to develop and implement their own plans. This trend partially nullifies local initiatives, undermines accountability, and diminishes the significance of citizen involvement in decision-making. Second, the capacity of the barangays to address some of the more serious issues in their areas is limited due to a lack of staff, professional competence, and resources. Many low-income settlements experience severe infrastructure problems, the effects of pollution, and a variety of other natural and man-made problems, particularly those related to urban development and habitation in an urbanised environment (Porio, 2011). It is further argued that the barangays do not take sufficient steps to develop residents’ skills or demonstrate sufficient initiative in matters of job creation, employment, and social development. Cooperation with non-governmental actors, particularly Scientific Production Associations, appears to be limited. Aside from the aforementioned issues, it is argued that the barangays do not appear to take the need for habitat improvement within the urbanised environment seriously enough. The challenges that informal settlers face frequently boil down to a decision between moving to the urban periphery or continuing to live in their current state. The mental and psychological ties to the neighbourhood contribute to the buildup of problems with urban development, adherence to sanitary and anti-epidemiological standards, etc. Consequently, neither the barangay representatives nor the local communities take the necessary initiative concerning these issues (Turok and Scheba, 2020).

The GD concept is widely reflected in Chinese policies, which have a mixed legal system and promote their own model of government while attempting to conform to global trends in civil society development and the rule of law. Despite differing perspectives on the nature of democracy as a political regime, Western countries are generally sceptical of the definition and operation of democracy in the Chinese legal system. Grassroots democracy in the PRC is also widely perceived as failing to produce Western-style political pluralism (Porio, 2011). These views appear progressive and promising in terms of Western democracy and generally accepted views on expanding the role of civil society in decision-making. Indeed, they are designed to promote greater freedoms and participation in policy formation and implementation. Attempts to put such a model into practice, however, are fraught with practical challenges caused by historically conditioned traits of the state structure, form of government, sustainability of state institutions, etc. What applies to a unitary state with a relatively homogeneous ethnic composition may be difficult to implement in countries with a diverse socioeconomic structure. Implementing such ideas would therefore present some real challenges for China as well as any other large nation with a diverse social structure. The key issue is how to build a unified nation while avoiding the trap of relying on a centralised government and an ossified bureaucracy incapable of handling multifaceted governance issues at various levels and scales (Skosyrev, 2020).

China has recently been associated with the term “non-Western democracy,” which has entered scholarly discourse amidst a debate over whether the PRC’s political system should be perceived as democratic. The interest in alternative forms of democracy stems from two factors: the failure of the so-called Global North’s democracy model to respond to contemporary challenges, as well as the shifting balance of power in the world and China’s economic rise. The emergence of the concept of “non-Western democracy” is now associated with the need to revise the definition of democracy and the recognition of its diverse configurations. Although hybrid forms of democracy that combine elements of Western democracy and authoritarianism are acknowledged as being possible, the debate over whether the Chinese political system fits the definition of democracy is still ongoing (Tang 2021). In the meantime, it appears that the benefits of traditional democracy are penetrating Chinese legal scholarship, policymaking, and lawmaking to a greater degree. Although the visible role of state structures in the PRC is well known (i.e., that they have historically tended toward centralisation and vertical power), the Chinese state has had to deal with increasingly multi-layered social changes, the decentralisation of the economy, and local governance in the post-reform era (Wu and Zhang, 2022).

From a formal point of view, the Chinese legislator does not define the relationship between the concepts of GG and the concept of local self-government, which in a sense complicates the understanding of the subtleties of meaning that the Chinese legislator and the subjects of political initiative put into the definition of GG. However, based on the political documents of the CCP, it can be argued that this is about both issues of self-organisation and grassroots initiative, as well as the process of governance at the local level. Of interest in this regard is the relatively recent CCP political act “Opinion of the Central Committee of the Communist Party of China and the State Council on Strengthening Grassroots Management Modernisation and Management Capacity (April 28, 2021) (Communist Party of China, 2021). The paper notes that GG is the cornerstone of national governance, and the overall promotion of township (street) and urban and rural community governance is a major project to realise the modernisation of the national governance system and governance capacity (Communist Party of China, 2021).

For China, as a country with a long history associated with a traditionally monarchical form of government and an East Asian regional context, the adoption of Western European democratic ideas dating back to antiquity was a kind of challenge to the familiar practices. In light of the existing priorities associated with the democratisation of society, the promotion of democratic values through their inclusion on the political agenda and the holding of democratic elections requires further development in a suitable socio-legal context. With a transitional society and the resulting increase in the plurality of social interests and exacerbation of social conflicts, the methods by which the ruling party governs the country are being called into question. It is clear that the state’s political elite has long recognised the value of democracy and the rule of law, and has attempted to promote an electoral model known as “public nomination and direct elections.” Additionally, this model appears to be an effort to conform popular democracy to the requirements of the so-called party model of democracy. It further shows how grassroots democracy gradually develops in the context of persistent dynamic interactions between competing political forces and influential groups (Belolyubskaya, 2017).

As previously stated, GG is not currently perceived as a single solution capable of being successfully adapted to various policy models. That said, there are obvious legitimate differences in how GG is perceived. The extent to which citizens are involved in grassroots governance appears to be due not only to different approaches to understanding grassroots democracy and grassroots governance and the mechanisms through which they operate, but also to the unique features of political systems, regional contexts, and historical assumptions (Weiping and Jiaxi, 2011; Wu and Zhang, 2022).

Talking about GD it should be noted that for Western countries, the latter is closer to the concept of direct democracy, i.e. unmediated legislative initiative. A study of the Chinese experience shows that the applicable approach does not eliminate the dependence of local civil communities on the state as the main agent of social and economic assistance (Porio, 2012; Wang and Yao, 2007; Xia, 2011). This study focuses on the convincing similarity between the categories of grassroots governance within the framework of Chinese political and legal reality and local self-government in the traditional sense. Nevertheless, from a formal point of view, the Chinese legislator does not equate these concepts with each other. At the same time, as can be noted in the Western legal doctrine GG implies the presence of a political component, which is indirectly demonstrated by the experience of countries such as Switzerland (Dalton et al., 2001; Fossedal, 2018).

The peculiarity of the political structure of Switzerland is that the latter, unlike many other countries of the world that prefer the principle of concentration of power, is built on the principle of separation of powers. However, this division is not formal, as in many other democratic countries, but real. In this case, the responsibility for what is happening in the state for the decisions made and their consequences lies not with one person (head of state or government), but with society, since all citizens take part in decision-making (Rochat, 2022).

Direct democracy has provided Switzerland with the image of a nation without a ruling elite, as a certain stratum of politicians who are distant in some way from their electorate. Direct democracy, as an example of grassroots democracy in action, ensures citizens’ right to participate directly in both grassroots government and state administration. It should be understood, however, that in Switzerland, the Philippines, and China, grassroots democracy and grassroots governance have somewhat distinct meanings. In the first case, one can safely speak not only of the exercise of local power but also of direct influence on political decision-making and policy-making at the municipal and national levels. The emphasis in the second and third cases is on increased interaction between state and local authorities (Fossedal, 2018).

China is a vast country with a long history of autocratic and feudal rule. Therefore, given the existing priorities for societal democratisation, the promotion of democratic politics and the holding of democratic elections necessitate further development in an appropriate socio-legal context. A consensus on the values of democracy and the rule of law has not yet been reached. This threatens grassroots democracy in a mixed legal system that supports its own model of government while also trying to keep up with global trends in the development of civil society and the rule of law. Although there are various interpretations of what democracy is and how it operates as a political system, Western nations are generally cautiously sceptical about how democracy is defined and implemented in the Chinese legal system.

Despite the fact that today it seems difficult to give an objective assessment of the effectiveness of GG, nevertheless, there are positive practices, the role of which should also not be ignored. It is noted that in the initial stages of the spread of COVID-19 throughout the country, village and district committees played a critical role in controlling various outbreaks of the pandemic, both through the introduction of quarantine and through the provision of public services when residents were forced to stay at home. While their efforts and methods to contain the spread of the disease have sometimes been controversial, they have generally received a positive response (Kapitsyn et al., 2022; Ye, 2021).

Despite a number of relatively balanced and consistent measures that have had a certain positive impact on Chinese society at the present time, it cannot be said that China and Western countries are moving in the same direction in matters of expanding the rights of citizens to self-government and legal initiatives. Contemporary scholarship suggests that grassroots democratisation in the PRC was largely a spontaneous decision (Skosyrev, 2020). The authorities took this step under the influence of the reformist sentiments of the early 1980s. Disputes about the purpose and significance of this project largely followed after the fact after the start of its implementation. At the same time, it should be understood that grassroots democracy in the PRC does not imply the creation of political pluralism along the lines of the Western model. The argument of GD critics in China is generally that the Grassroots Grassroots have the right to exercise democratic rights only under the leadership of the CCP (Skosyrev, 2020). It is argued that the Chinese Communist Party does not set goals related to the democratisation of the country. However, an interest in the development of democracy at the grassroots level may be a harbinger of a large-scale process of political liberalisation. Speaking about the extent to which grassroots communities are able to imbue democratic ideals and whether we should expect them to have a more accurate understanding of the concept of democracy, it would be very difficult to give an unambiguous answer. However, even taking into account the measures taken to develop the GD, it would be premature to expect political liberalisation across the country in the coming years (Skosyrev, 2020).

Using the Philippines as an example, it should be noted that the country currently has a grassroots governance system with some distinctive features that are practically applicable to developing countries outside of the South and East Asian region. Currently, the compact settlement of marginalised populations without access to social benefits is a challenge for many countries. The Philippines faces unique challenges as a result of its rapid population growth in a region plagued by serious environmental, economic, and social threats (Turok and Scheba, 2020). Grassroots forms of self-organisation, such as barangays, can give poor and marginalised groups a voice in decision-making and provide practical assistance, thereby enhancing their access to social benefits and promoting social development. This, in turn, can help counter authoritarian tendencies in national politics and make it more difficult for powerful elites who gravitate toward authoritarian regimes to dominate later. These kinds of institutions can significantly advance the active growth of civil society.

Conclusions

Exploring the GG phenomenon, a very important feature should be noted—the fact that at present there is no legal or exhaustive scientific definition of what should be understood as what is called GG. At the same time, analysing the views of modern researchers, it becomes obvious that today it is quite difficult to unify definitions and come to a common understanding of the term since politicians within national jurisdictions often put different meanings into this concept.

The GG is currently a complex symbiosis of the concepts of local government, civic activism, and elements of direct democracy. Existing as a theoretical category, its mechanisms do not yet have legal institutionalisation in any of the countries considered. The paper notes that at present the category of GG is not represented at the regulatory level, existing as a political guideline. At the same time, this category correlates with the traditional Western ideas about local self-government. In the PRC, the modern specificity of GG is associated with the expansion of powers in the field of local self-government with an emphasis on the interests of communities. Due to multi-level management, the state involves social and market entities in management processes at different levels, but at the same time retains the ability to strategically intervene. In Switzerland, the specific implementation of the GG, expressed through the use of such forms of direct democracy as a referendum and legislative initiative, is presented in its entirety. The referendum allows Swiss citizens to reject measures taken by their representatives, while the initiative gives the Swiss the opportunity to personally, independently of the legislature, enforce laws. From the point of view of issues of social development, the examples of the countries considered can show the difference between the traditional worldview and the classical Western European idea of the democratic structure of society, which will make it possible to better understand the existing obstacles in the development of modern democracies.

This article suggests that, as part of a study of grassroots governance, the concept of GG does not yet have a clear formal framework or definition. There is currently insufficient research to improve the understanding of the differences between direct democracy and grassroots governance. This article draws several conclusions that contribute to the ongoing debate about citizens’ support for various grassroots governance processes. It is critical to recognise that, despite differences in practical approaches, grassroots governance creates many potential social development benefits for its participants and society at large.

The concepts of grassroots democracy and grassroots governance may have evolved in different historical and political contexts. At the moment, it is difficult to see GG as a single solution that can be successfully applied to various political models. Therefore, the examples of grassroots governance approach from China, the Philippines, and Switzerland demonstrate how different grassroots governance arrangements can be implemented depending on the historical–political context. In the first case, one can safely speak not only of the exercise of local power but also of direct influence on participation in political decision-making and policy formation at both the municipal and national levels. In the second and third cases, it is more a matter of improving the interaction between state and local governments. Given the cases examined, it is clear that none of these examples can be regarded as a model for how to put grassroots governance into practice. The connection between the notions of grassroots democracy and grassroots governance could be the subject of future study.