ABSTRACT
The problems and obstacles have been carefully analysed many times by legal comparatists. The extent to which administrative law can be compared is sometimes questioned because of its strong national character. National administrative traditions that have had a major influence on other administrative systems are identified at different levels of abstraction by postulating three decisive national pathways to a systemic grouping of countries sharing a common administrative inheritance. All the special administrative law traditions, the legal families or the convergence/divergence dichotomy could probably offer an adequate analytical framework for our comparative study. Effective legal protection is recognised by most national legal systems, specified by national legislation, and explained and extended frequently by jurisprudence of the constitutional or ordinary courts, even if the national constitutions do not contain any reference to the exact concept. Fundamental rights have a universal character, so the procedural safeguards of legal protection are not usually specified for administrative law.
