L'idealtipo di procedimento amministrativo europeo e le influenze delle tradizioni giuridiche nazionali

In European administrative law a general administrative procedure act doesn’t exist, but there are many sectoral rules and principles developed by the Court of Justice. There is no doubt about the need for general legislation. However we can find numerous applicative problems, especially in the procedures requiring the joint participation of EU institutions and national bodies. For these proceedings there is a need to coordinate the European rules with the ones of the national legal traditions. This work compares the main aspects of the rules on proceedings in the European Union with those applied in the most relevant jurisdictions. The author analyzes the possible convergences basing on the distinction between the open and the narrow investigation model.