Britain's existing 28-day limit on holding terror suspects without charge is already far longer than that for any comparable democracy, according to a study to be published today.

The survey, by the human rights organisation Liberty, was carried out by lawyers and academics in 15 countries. It shows that the four-week maximum in Britain outstrips limits in countries that have also suffered al-Qaida inspired terrorist attacks in recent years, including the United States, Spain and Turkey.

Although police in these countries also face increasingly complex terror plots with growing international dimensions, their maximum periods for pre-charge detention remain as short as 48 hours in the US, five days in Spain and seven and a half days in Turkey.

The findings are released as MPs await the publication of a new counter-terrorism bill that will propose extending detention without charge beyond 28 days.

Police chiefs have argued that complex investigations, including trawling computers and telephones for evidence of terrorist plots, mean they need the option of holding suspects for longer.

But critics have expressed concern that police have failed to bring forward compelling evidence to show the need for an extension.

The home secretary, Jacqui Smith, is determined to avoid a repeat of the humiliating Commons defeat suffered by Tony Blair two years ago when he proposed a 90-day limit and saw 49 Labour MPs rebel.

Ministers have indicated they would favour a maximum of up to 56 days, but no government position has been made clear. There is evidence that Gordon Brown has not yet formed any strong personal opinion and he is said to remain "genuinely open-minded" on his preferred option.

Liberty's experts around the world found that in comparable democracies the closest equivalent to a charge for those who have been detained in connection with terrorist activities must happen within days and not the months or even the years claimed by those who want to double the British limit to eight weeks.

The absence of a final decision has been reflected in a slippage of the publication date of the counter-terror bill. It was expected to appear by the end of this month but has now been pencilled in for December-January, with Smith only saying publicly that she hopes it will happen by Christmas.

The home secretary has claimed that carrying out international comparisons of pre-charge detention limits are so complex that they are on a level with doing a PhD thesis, while the Metropolitan police commissioner, Sir Ian Blair, has claimed that in countries such as France and Germany judicial oversight allows people to be detained for years.

Shami Chakrabarti, the director of Liberty, said any extension of pre-charge detention would put Britain even further out of line with comparable democracies around the world: "The new prime minister is neither Tony nor Ian Blair. I have every hope that this new, damning evidence, alongside proportionate alternatives to lengthy pre-charge detention, will persuade him to think again."

She said the Liberty study "explodes self-serving assertions about extended detention in inquisitorial Europe and other western democracies. It makes embarrassing reading for all of us in the land that gave Magna Carta to the world."

The human rights organisation acknowledged that comparisons with other common law systems such as in Canada, New Zealand and Australia were more straightforward than those with inquisitorial civil law systems such as France and Germany, but said it had asked legal experts in each country to identify the closest equivalent to pre-charge detention.

"We found that the closest equivalent to a charge must happen within a matter of days, not months or years as Sir Ian Blair and others have suggested," the Liberty study concludes.

It also warns that any extension of pre-charge detention in Britain could have broader implications around the world and give the green light to other governments such as Robert Mugabe's in Zimbabwe to pass more draconian anti-terror laws: "Some states, and some individuals seeking to radicalise Muslim youths also might use the disparity to undermine the UK's claim to civility and moral authority."

Source: The Guardian

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