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Das öffentlichen Diensrecht aus der Perspektive der vergleichenden Verwaltungswissenschaft


  • Jacques Ziller


International comparisons of Civil Services usually overlook the difficulties due to differing definitions of the civil service in national legal systems. Comparative statistics are therefore extremely misleading, as they are at best based on formal-legal criteria instead of being based on functional definitions. Beyond the issue of numbers, comparing the legal regimes of civil services can also be misleading if the constitutional framework is ignored, as demonstrated by the link between the constitutional principles applying to the Royal prerogative in the UK,and if attention is centred on the source of regulation – as demonstrated by the case of the socalled privatisation of the Italian civil service. Furthermore, any comparison between civil service regimes should also take into account the content of the relevant regulations and compare them with the rules and principles applicable in the same country’s labour law.There is no such a thing as an international common core of civil service regulation

Suggested Citation

  • Jacques Ziller, 2006. "Das öffentlichen Diensrecht aus der Perspektive der vergleichenden Verwaltungswissenschaft," EUI-LAW Working Papers 9, European University Institute (EUI), Department of Law.
  • Handle: RePEc:erp:euilaw:p0045

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    public administration; France; Germany; Italy; U.K.; law; political science;

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