域外行政公益诉讼制度之特征

行政公益诉讼发展到今天．在全球基本已形成两种典型的模式，即英美法系模式和大陆法系模式。两大行政公益诉讼模式很难说孰优孰劣．他们都是从自己的法律制度中演化出来的新型诉讼，对传统的行政诉讼制度构成一定的挑战。尽管各国（地区）行政公益诉讼的表现形式和称谓不尽一致，但却有许多共同特征：

Comment on Administrative Public Welfare Action(Part One)

The amendment of Administrative Procedure Law has been put on the agenda, and the direction of the administrative public welfare action has come to a stage that can not be avoided. In recent years, as to the issue, different people have different opinions: some peolpe tout it, some give it a cool thinking, and some oppose it. In order to eventually make a solid theoretical foundation for China's administrative system of public welfare action, there are a lot of issues need further study. Here is a comment on it, which is part of the achievement of Professor Huang Xuexian's item funded by the Ministry of Justice Research on the Administrative Public Welfare Action(06 SFB5007). Because it is a comment, different opinions are allowed, whose purpose is to provide some reasonable advice for its amendment. Here it will be adapted through two parts.