Abstract
This paper examines the creation and the evolution of standards of review in four jurisdictions (France, Italy, United States and Canada). This historical perspective will demonstrate (i) that the judicial self-restraint can have different meanings; and (ii) that while in certain jurisdictions the deferential standards of review are disseminated, in others they are experiencing a clear decline.
Keywords:
dynamics of deference; judicial review; public administration; creation and evolution; comparative law