境外行政主体制度研究

The theory and system of the administrative subject in foreign realm

行政主体理论自行政法成为公法重要组成部分时便成为行政法几个核心理论之一。自《中华人民共和国行政诉讼法》实施以来,行政主体理论研究成为我国行政法理论研究的重点之一。我国关于行政主体的内涵及外延,学术界各抒己见,至今缺乏统一的论断。境外一些行政法理论发达国家和地区的行政主体制度对于我们具有借鉴意义。

The theory of the administrative subject has become one of the core part of the administrative law study since the administrative law as an important part in public law. Since the legislation of the ADMINISTRATIVE PROCEDURE LAW OF THE PEOPLE'S REPUBLIC OF CHINA came into effect in 1989,the study of the theory of the administrative subject has become an important field in the administrative law study in China. There are different kinds of theories about the connotation and extension of the administrative subject and there still has no uniform conclusion. This article mainly attempts to find out the methods to solve this problem by introducing the system of the administrative subject in other countries and areas.