Output details
20 - Law
University of Essex
Les contrats publics anglais et français entre technique et loyauté
This paper compares the places of parties’ autonomy in public contracts in France and England. It suggests a framework to map the formal legal rules and moral values directing parties’ behaviour in these contracts. Thanks to the implementation of European directives, France and England have similar rules regarding the regulation of procurement and the control that third parties, such as rejected bidders, can exercise over them. However, factors other than the law which influence parties’ autonomy, such as loyalty, remain rooted in the specificities of each legal system. Therefore this paper sharpens our understanding of the Europeanisation of public contracts.