La responsabilità civile della pubblica amministrazione: profili comunitari e comparati

The article aims at analysing, in a comparative perspective, the civil liability of public authorities. It focuses on three different issues: the first one deals with the relationship between illegal act and liability; the second one is related to the relevance of discretionary powers in the matter; the third one is about the connections between the public law remedy (judicial review procedure) and the tort action for damages. The study explores the solutions provided for in the EU, French and UK administrative systems.