西方两大法系行政法基本原则之比较

Through in-depth comparative study on the basic principles of administrative law of the two western legal systems, the paper reveals that each of the two systems has its own distinct basic principles of administrative law. On the other hand, these principles share some common characteristics and follow some universal rules. The basic legal principles of administrative law common to all modern western countries can be summed up as the following three principles: legally prescribed administration, proportional administration and administrative justice. These three principles together constitute the basic standards universally observed by modern western governments in their exercise of power.