A Comparative Study of the Basis of Judicial Review of the Acts of Administrative Agencies and Assessment of Regularity Models in Legal Systems of Iran, England, France and Germany

Existence of a complete and accurate system for review and control is one of the important and critical elements in a safe and effective management. One of the most important forms of review is judicial review of the actions of administrative agencies that have been evolved and developed on the basis of rule of law, duty of public officials and institutions to accountability and the establishment of democracy in recent decades. Regulatory models in some legal systems of the European Union have been distinguished depending on being defined on the basis of structure or jurisdiction. In line with the ultimate goal of the EU members to integrate their laws and regulations, the glimmer of hope in creating a common and uniform model in the area of judicial review of the acts of administrative agencies is taking shape. In the Iranian legal system, following some leading countries in this context such as France and Germany, judicial institutions are established by legislature each of them having their own functions. In this study, it has been tried to consider the basis and appraisement of judicial review models in some countries of the European Union and Iranian legal system and also to compare their similarities and differences.