mahdi hsanvand

Comparative Administrative law is a difficult subject. It is necessary to steer a course between the assumption that all systems are singular, shaped by a plethora of distinctive features that are never replicated elsewhere; and the equally extreme assumption that differences are merely on the surface, such that if propositions are stated at a sufficiently abstract level, then there will be commonality between all systems. The ascription of cause and effect when considering the rationale for differences is equally challenging, and is the principal focus of this review article, which considers the strengths and weaknesses of a structural explanation for divergence in administrative law in different countries.Study of comparative administrative law reveals commonality and difference between the systems studied. That is axiomatic and self-evident. The depth of the resulting similarities and divergences may be difficult to estimate, the explanation for them even more so.