OLIY TA'LIMDA MUSTAQIL TA'LIMNING HUQUQIY INSTITUTLASHUVI: TARIXIY-HUQUQIY QIYOSIY TAJRIBA

Annotasiya

The article analyzes the process of the formation of self-directed learning as a legal institution in comparison with the experience of CIS countries. Most post-Soviet states began building their education-law systems from the Soviet administrative-command model, yet each chose its own path toward turning self-directed learning into a legal institution. Uzbekistan's transition to the credit-module system is compared with the experience of Russia and Kazakhstan. The article shows that Russia follows an institutional-autonomy model, Kazakhstan a centralized-normative model, and Uzbekistan an intermediate variant. It finds that in all three states the quantitative dimension of independent work was regulated before the qualitative one, that the concept of independent work is understood differently, and that civil-law protection practice remains underdeveloped. The comparative-legal method allows a functional comparison of the normative acts of the three countries. On this basis, proposals are made for balancing institutional autonomy with national accreditation and quality control. The study argues for creative adaptation rather than mechanical transplantation of ready-made models.