using a comparative-analytical approach, examines the institutional position and structural challenges of the right to appeal in two important administrative justice institutions, the Iranian Administrative Court of Justice and the Turkish Council of State. The main issue of the research is to what extent these institutions have been able to effectively guarantee the right to appeal in practice and what institutional and functional obstacles exist on the path to the full realization of this right. In fact, analyzing the quality of the performance of these institutions in different legal and structural conditions can help identify existing gaps and weaknesses and provide appropriate solutions for improving the administrative justice system. The main goal of the research is to assess the extent to which this right is realized through the structures and performance of these two institutions and to identify existing obstacles. The research data were collected by analyzing laws, judicial decisions, and institutional structures and were examined using a descriptive-analytical method. The main focus is, and level of functional independence of these institutions. The results show that the Iranian Administrative Court of Justice faces problems such as centralization, weak specialization in the composition of judges, and institutional dependence, while the Turkish State Council, despite its structural independence and broad jurisdiction, faces procedural complexities, slow processing times, and political interference. The findings emphasize the need to reform structures, strengthen the independence of institutions, and establish preventive mechanisms, and can pave the way for a review of administrative justice systems with similar characteristics.