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date: 16 October 2019

Abstract and Keywords

Comparative administrative law is a long-standing discipline. The study of other administrative law systems both in order to understand one’s own system better and to find models for improvement has been occurring for over 150 years. It is closely bound up with national institutions and traditions, as well as national constitutional values and ways of operating. Any comparative approach has to take full account of the institutional context in which a particular problem or procedure occurs and to ensure that full account of these nationally specific features is taken before any attempt is made to generalize or compare. This article describes the scope of the subject, the values served by administrative law, and influences shaping administrative law. It also compares the powers, organizations, and procedures of the administration, as well as legal redress.

Keywords: administrative law, judicial review, legal redress, private law, public administration ombudsman

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