Luu Lan Phuong Nguyen
Artificial intelligence is rapidly reshaping civil justice systems worldwide. While digital technologies have long been used to enhance court efficiency, the integration of AI into judicial decision-making and case management raises persistent concerns regarding transparency, procedural fairness, and judicial accountability. Existing scholarship, howe-ver, broadly examines AI governance within individual jurisdictions, often focusing on regu-latory frameworks or specific institutional experiments, without systematically comparing how different civil justice systems embed AI within their procedural and governance struc-tures. This article addresses this gap through a comparative analysis of AI-enabled civil jus-tice in three contrasting jurisdictions: the European Union, China, and Singapore. Rather than assuming convergence toward a standard model of AI-driven justice, the article con-ceptualizes AI integration as an institutional design problem shaped by procedural values, governance arrangements, and capacity constraints. Methodologically, the study adopts a qualitative comparative approach, drawing on legislative texts, institutional reports, and existing empirical evaluations. The analysis reveals three distinct institutional logics. The EU prioritizes human-centric procedural safeguards and accountability, often constraining the scale and speed of AI adoption. China adopts an efficiency-first model of judicial mo-dernization, embedding AI deeply into court infrastructure to enhance capacity and consis-tency, while narrowing opportunities for procedural contestation. Singapore occupies an intermediate position, pursuing pragmatic, governance-driven innovation grounded in pro-fessional responsibility and incremental adoption. Sum, the article demonstrates that there is no one-size-fits-all model and that AI redistributes procedural risk across participation, accountability, and efficiency in institutionally path-dependent ways.