Grundelemente eines handlungsformbezogenen Verwaltungsrechtsvergleichs in Europa

The German tradition to organize administrative law according to the legal instruments used by the authorities is also fruitful to analyse foreign jurisdictions. The scope of the comparative study includes the five most important countries in Western Europe: Germany, France, Spain, Italy and England. The analysis covers the three main instruments of administrative action, i. e. single case decision, contract and rulemaking, and the pertinent rules on procedure, on repeal or modification and on enforcement. The choice of the instrument also affects the mechanisms of internal review and of judicial protection. The comparison helps to understand common European standards but also some peculiar features of national administrative law.