THE OUTSOURCING OF PUBLIC ACTIVITIES AND ITS LIMITS IN THE COMPARATIVE LAW

This study proposes to perform a short presentation of the limits in which the externalization of the public activities may be performed in a few representative countries in the Romano-German law system (France, Germany, Spain, Italy) and the Anglo-Saxon law system (Great Britain). Although, in principle, the public activities that involve the exercise of sovereignty (justice, police, army) cannot be performed by the private sector, we will observe that the are different nuances from country to country. Finally, the compared analysis is exploited in the Romanian law through legislative (lege ferenda) proposals.