ABSTRACT
Even if Goethe thought that ‘comparing is just an easy way for the ignorant to avoid making decisions’, most French and British academics as well as other European colleagues would consider that there is an urgent need for improving mutual knowledge through comparison. Thus although there are apparently comparable problems in both countries and considerable exchange of information about them and the methods of dealing with them in a western democratic environment, there are still continuing debates about their nature and the differing legal and institutional frameworks within which the two societies operate to manage and resolve such problems.
