“…The analysis is guided by two approaches that explain judicial controls of government's actions. On the one hand, it is guided by the comparative administrative law approach, which studies the legal doctrines that rule a judiciary system in order to distinguish institutions of administrative justice under the common law tradition from those rooted in the French droit administratif tradition (Baum, 2011;Betancor Rodríguez, 1994, 2010aBignami 2012Bignami , 2016Cane 2011;Ginsburg & Wright, 2012;Solanes Mullor 2016). On the other hand, the comparative analysis is also guided by an institutional approach, which highlights how the given design of a court's system (e.g.…”