A comparison between the water law reforms in South Africa and Scotland: can a generic national water law model be developed from these examples?

Many governments have been prompted by water shortages and inadequate infrastructure to re-assess their water management regimes. The aim of this article is to compare the reforms made in two very different nations, South Africa and Scotland, and to examine the best parts of each with a view to establishing a model national water law framework. The article assesses the hydropolitics of both countries, along with the reforms and their implementation, and critically compares these in the context of international best practice and relevant regional agreements. It concludes that a model framework could be implemented in more affluent nations, irrespective of climate, but would not be workable in very poor nations.