, Comparison within Multi-Level Polities and Governance Regimes

Administrative law comparison plays a specific institutional role in the framework of the League of Nations/UN on the one side and in the Council of Europe and the EU on the other. Further enquiry in the methodologies used might show how comparison in the EU framework is developing in the direction of H. Patrick Glenn’s proposals of a new aim for comparative law. The use of comparative law methodology remains generally speaking rather weak in the framework of global governmental organisations, even in International administrative tribunals. It is on the contrary quite developed in the framework of the Council of Europe, with limitations due to the intergovernmental nature of the organisation. In the framework of the EU administrative law comparison has had a paramount role since the nineteen fifties in the ECJ’s jurisprudence and is constantly developing in legislation and rulemaking.