Pathology of Features of Iran Administrative Contract in the Compared with France and England Law

Administrative contracts are legal institutions that have been discussed in field of public law in the legal Roman – German system، France in particular، and it is said that in the country it has increasingly been developed and now it is an eloquence situation. But the institution have not been developed in Common law system (England in particular); and there is a kind of impossibility in acceptance of the institution in Iranian legal system. In first view، yet، all contracts have been discussed in private law field in Iran and England systems. In this paper، we have discussed to pathology of features of administrative contract in Iran in the light of France and England Law. Thus، with focus to the nature of administrative contracts، it has been said important four features to the contracts in four section and has been concluded that although there are similarity in the features; but there are important difficulties in Iranian legal system، such as lack of professional courts and non–harmonic approach among judicial، legislative and idea systems، so that it can said that the features have not been instituted in our legal system.