This wide-ranging comparative account of the legal regimes for
controlling administrative power in England, the USA and Australia
argues that differences and similarities between control regimes
may be partly explained by the constitutional structures of the
systems of government in which they are embedded. It applies
social-scientific and historical methods to the comparative study
of law and legal systems in a novel and innovative way, and
combines accounts of long-term and large-scale patterns of power
distribution with detailed analysis of features of administrative
law and the administrative justice systems of three jurisdictions.
It also proposes a new method of analysing systems of government
based on two different models of the distribution of public power
(diffusion and concentration), a model which proves more
illuminating than traditional separation-of-powers analysis.
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