نوع مقاله : مقاله پژوهشی
نویسنده
دانشگاه آزاد بندرعباس
چکیده
کلیدواژهها
موضوعات
عنوان مقاله [English]
نویسنده [English]
It seems Until after World War II, most studies and manuals of comparative law or foreign legal systems were always the work of specialists in comparative civil law or comparative commercial law, and the fields of public law were not the subject of comparative study. This underdevelopment or late development of the comparative branches of public law (here specifically, constitutional law and administrative law) is partly caused by the late development of public law itself compared to private law, which of course is a result of the characteristics that distinguish the public law as the law of the relations between the rulers and the governed in general, from the law governing the relations of private individuals. According to author, Although all the considerations or limitations that are made by researchers in all fields of comparative law and that occur in the numerous disagreements that exist, especially in the methodology of comparative law, also appear and manifest in comparative public law, but, the neighborhood of public law and politics and the dependence or greater sensitivity of at least constitutional law to domestic and international political developments, has given characteristics to comparative public law (constitutional law and administrative law) and its expected function, which distinguishes it from other branches of comparative law and forms the subject of this article. This article, in an analytical-descriptive way, seeks to identify the variables that the author thinks are the indicators of comparative public law and explains the process of its development and evolution.
کلیدواژهها [English]