ABSTRACT
This chapter aims to test the assumption that the granting of procedural guarantees by national constitutions was, over time, both being expanded within countries and being diffused worldwide across all countries. Succinct accounts of the extension of due process guarantees provided by the United States court system and under English administrative law have been provided by Mashaw and Schwartz, respectively. It focuses on the need to seek out patterns of differentiation as these might be manifested by subsets of countries viewed temporally, regionally, or culturally. In Great Britain, over many decades starting in the late nineteenth century, the courts used the principle of natural justice to limit arbitrary action by government in fields such as housing and with regard to dismissal from office. As constitutionalism spread early in the twentieth century and became an object of systematic study, collections of comparative constitutions became quite common in English.
