한국 행정소송제도와 일본 신행정소송제도의 비교 연구 － 정부안 · 대법원안을 포함하여 －

This article is written about a comparative study on the Korean-Japanese administrative suit system. Japanese administrative suit system was enacted in 1962. Thereafter it have not been amended until 2004. Japanese neo-administrative suit system in 2004 is mainly as follows ; First, it made various new administrative litigation types. They are called obligatory litigation and injunctive litigation. Second, the scope of standing was enlarged. Third, the defendant was changed from administrative agency to administrative subject(e.g. state and local government). In Korea the administrative suit system is working on revision. And Japanese one may be the model of Korean neo-administrative suit system. Therefore, I aim for a comparative study on the Korean-Japanese administrative suit system. Through the study we may acquire many suggestions about the revision of Korean administrative suit system.