Comparative Public Administration: USA, UK, France and China

What the official syllabus says

Main Examination, Paper III (General Studies III), Unit II - Concepts, Issues and Dynamics of Public Administration, under the heading “Comparative Public Administration”:

• Features of Administrative Systems of U.S.A., U.K., France and China.

Topics in detail

Comparative public administration as a field

• Meaning and purpose of comparing administrative systems
• Fred Riggs' contribution and the Comparative Administration Group

United States of America

• Presidential system, separation of powers and checks and balances; federal structure
• The President as chief executive; executive departments and the Cabinet; Executive Office of the President
• Independent regulatory commissions, sometimes called the “headless fourth branch”
• Civil service: the spoils system, the Pendleton Act (1883), the merit system, the Civil Service Reform Act (1978) with the Office of Personnel Management and the Senior Executive Service
• Senate confirmation of senior appointments; legislative oversight; the Government Accountability Office
• Political appointees in the top layers of departments; the Hatch Act (1939) restricting political activity of federal employees
• Administrative law in the common-law tradition: ordinary courts review administrative action

United Kingdom

• Unwritten constitution, parliamentary sovereignty, the Crown, Prime Minister and Cabinet
• Departments headed by ministers with permanent secretaries; the civil service as permanent, neutral and anonymous
• Northcote-Trevelyan Report (1854), Fulton Committee (1968), Next Steps executive agencies (1988), the Citizen's Charter (1991)
• Ombudsman (Parliamentary Commissioner for Administration, 1967); National Audit Office
• Civil Service Commission and the Civil Service Code; merit-based recruitment
• Devolution to Scotland, Wales and Northern Ireland; local government

France

• Fifth Republic (1958): semi-presidential system with a President and a Prime Minister
• A unitary, historically centralised state; decentralisation laws from 1982
• Prefects in the departments and regions as agents of the state
• Administrative law (droit administratif) and administrative courts; the Council of State (Conseil d'État) as adviser to the government and highest administrative court
• Elite civil service: grands corps, ENA (1945), replaced by the Institut national du service public (2022)
• Court of Audit (Cour des comptes); the Defender of Rights (Défenseur des droits) as an ombudsman

China

• Leading role of the Communist Party of China; party and state structures side by side
• National People's Congress as the highest organ of state power; the President
• State Council headed by the Premier: ministries and commissions
• Local government: provinces, autonomous regions, municipalities under the central government, special administrative regions
• Cadre management and the Party's Organisation Department; the Civil Servant Law
• Planning: five-year plans and the National Development and Reform Commission
• Anti-corruption: the National Supervisory Commission (2018) alongside the Party's discipline commission

Points of comparison

Overlaps

Use these systems for contrast with India's: civil service neutrality and minister-civil servant relations are in Union Government and Administrative Institutions.