Abstract

This paper outlines some basic approaches to identifying frameworks of comparative public and more specifically administrative law research. It first argues that establishing comparative frameworks is a task ubiquitous to legal methodology. Identifying the framework of research is the decisive factor identifying the comparators and allowing assessment of similarities and differences. The finding of relatively ubiquitous nature of the comparative method is the backdrop to the discussions in this paper, critically reviewing three major frameworks identified by the objectives of the comparative approach: law as ‘category’, as ‘source’, and as ‘variable’.

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