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On Civil Service Reform during Margaret Thatcher Government and Its Ideological Origins By He Shengjing A Thesis Submitted to the Graduate School and College of English in Partial Fulfillment of the Requirements for the Degree of Master of Arts Under the Supervision of Professor Chen Hansheng Shanghai International Studies University April, 2009 Acknowledgements I would like to express my great appreciation to the teachers and professors who have instructed me in the two years of my postgraduate study, to my respectful supervisor Professor Chen Hansheng in particular, not only for his delicate guidance and patient checking of the paper but also for his priceless enlightenment which helped me pave the way to my fixated life outlook to a large extent. My special gratitude is also delivered to Professor Wang Enming for his patient checking of my paper in terms of the overall outline, title rearrangement, and academic standard. Last but not least, I would like to give my gratitude to my heartfelt friends with whom I have spent the harmonious and delightful campus life and my supportive family from whom I have been indulged with resourceful understanding and encouragement. For this, I thank them. i 摘要 作为最早建立现代文官制度的国家,英国一直备受世界关注。尤其在撒切尔夫人 任职期间对文官制度进行的大刀阔斧的改革不仅对英国产生了深远的影响,在国际上 也引起了强烈的反响,使英国的文官制度再次成为世界各国文官制度建设的楷模。因 此,对英国的改革实践进行系统地梳理和分析,对于我们更为深刻地理解和把握西方 国家文官制度改革的理论逻辑有着重要的现实意义。本文试图从历史的角度对英国文 官制度改革进行梳理,重点介绍撒切尔政府时期的文官改革措施,并深入分析改革的 意识形态起源,以期能对我国的文官制度改革有所借鉴。 本文第一章简要介绍英国近代文官制度的历史沿革及撒切尔政府时期的文官制 度改革背景。十九世纪中期《诺-屈报告》的发表标志着英国近代文官制度的确立, 进入二十世纪后,文官的表现和文官制度本身日益受到社会的批评。从二十世纪六十 年代起,随着《富尔顿报告》的出台,英国率先开始了文官制度的现代化改革。到二 十世纪后半期,英国的经济,财政危机及社会结构的变化使政府陷入困境;而文官制 度的繁冗机构,通才制度及严重的官僚作风更使其成为撒切尔政府改革的矛头。 本文第二章讨论撒切尔政府时期对文官制度大张旗鼓的改革,改革的具体措施主 要包括雷纳评审, 《下一步行动方案》等。雷纳评审是对英国政府机构运转情况进行 的一次大规模调查研究,为后续改革提供了有益的经验和具体的建议;而《下一步行 动方案》的出台,特别是执行机构的设立从根本上动摇了文官制度。撒切尔政府时期 文官制度的改革可以说是一次与传统决裂的转型。同时也在国际上产生了深远的影 响,成为许多国家二十世纪最后二十年文官制度改革效仿的对象。 本文第三章深入探讨撒切尔政府时期文官制度改革的意识形态起源。英国保守, 渐进的文化传统对文官制度改革的特点起到了决定性的作用;而撒切尔的政治思想, 及英国的政治文化传统如对政府权利的限制,政府运转方式的特殊性,以及对行政的 价值追求等则推动了文官制度的改革。在文章的最后,笔者简要分析撒切尔政府文官 制度改革所带来的成效及改革存在的问题,并在结论中总结其对中国未来文官制度改 革的启发。笔者认为研究撒切尔政府的文官制度改革不仅对于了解英国文官制度、探 索其自身发展的规律性具有重要意义,而且对我国当前进行的文官制度改革也具有积 极的借鉴意义。 关键词:英国文官制度,撒切尔政府,意识形态起源 ii Abstract As the birthplace of modern civil service system, the United Kingdom has always stayed in the focus of world’s attention. Margaret Thatcher’s radical and enduring reforms on civil service system in particular have imposed far-reaching influence both in Britain and across the world, rendering British civil service the model for other nations once again. Thus, it is of extreme significance to conduct a systematic analysis of British civil service reform, with an aim for a profound understanding on the theoretical logic of western civil service reforms. In this paper, the author first adopts a historical approach as for the introduction of the history of British civil service reforms, with an emphasis on the reform measures taken by the Thatcher Government. What follows is the in-depth discussion about the ideological origins for Thatcher’s reforms, from which the author draws implications for its application in China’s civil service reform. In the first chapter, a brief review is carried out on the history of British civil service reforms, together with the introduction on the background of Thatcher’s reforms. The release of Northcote-Trevelyan Report in the mid-19th century marked the establishment of British modern civil service system. However, in the 20th century, the civil service system as well as its civil servants began to be the target of public criticism. Finally the issuance of Fulton Report in the 1960’s initiated a modern reform for British civil service. In the latter half of the 20th century, the economical and fiscal crisis as well as the changes in social structure reduced the British government into plight; meanwhile, the drawbacks within civil service system such as its overstaffed organization, generalist system and deteriorating bureaucracy led to the civil service reform. In the second chapter, an in-depth exploration is conducted on Thatcher’s reforms, with reform measures such as the Rayner Scrutiny Program, and Next Steps. The Rayner Scrutiny Program is a large-scale survey about British government operation, which provides the following reforms with beneficial lessons and concrete suggestions; while the implementation of Next Steps, especially the establishment of Executive Agencies shakes the civil service in its fundamental sense. It can be concluded that Thatcher’s reforms result in a substantial transformation in the civil service, symbolizing a rupture with the iii traditions. Its far-reaching and world-sweeping impacts render the reform a model for other nations to follow in the last two decades of the 20th century. In the third chapter, a thorough discussion is held on the ideological origins of Thatcher’s reforms, in which the conservatism and gradualism cultural traditions play a definitive role for the civil service reform while Margaret Thatcher’s conviction politics as well as British political cultures such as limitation on government power, the particularity of government operation and the pursuit of administrative values help facilitate the civil service reform. In the end, the author analyzes the effects and problems of Thatcher’s reforms, with implications drawn on China’s future civil service reform. In the author’s opinion, the study on Thatcher’s civil service reform not only helps a better comprehension about British civil service system, which is conducive to the exploration of its law of development, but also serves as an inspirational reference to China’s civil service reform. Key words: Home Civil Service, Margaret Thatcher Government, Ideological Origins iv Contents 摘要 ............................................................................................................................................................ i Abstract ................................................................................................................................................... iii Introduction ............................................................................................................................................. 1 Chapter One. Background to Margaret Thatcher’s Civil Service Reforms....................................... 4 1.1 A Brief History of Home Civil Service Reforms....................................................................... 4 1.1.1Northcote-Trevelyan Report .............................................................................................. 4 1.1.2 Fulton Report.................................................................................................................... 6 1.2 Background to Thatcher’s Reforms ............................................................................................. 8 1.2.1 Inherent Problems within the Civil Service System ......................................................... 8 1.2.2 External Environmental Changes of the Civil Service System....................................... 11 Chapter Two. A Brief Introduction to Thatcher’s Reforms............................................................... 15 2.1 Downsizing................................................................................................................................ 16 2.2 Scrutiny Program....................................................................................................................... 17 2.3 Next Steps.................................................................................................................................. 19 2.4 Structural Reorganization .......................................................................................................... 21 Chapter Three. Ideological Origins of Thatcher’s Reforms .............................................................. 24 3.1 The Definitive Role of Cultural Traditions................................................................................ 24 3.1.1 Conservatism .................................................................................................................. 25 3.1.2 Gradualism...................................................................................................................... 27 3.1.3 Evaluation of Performance ............................................................................................. 28 3.2 The Facilitative Function of Political Culture ........................................................................... 29 3.2.1 Conviction Politics ......................................................................................................... 29 3.2.2 Limitation on Government Power .................................................................................. 30 3.2.3 Particularity of Government Operation .......................................................................... 32 3.2.4 Pursuit of Administrative Values.................................................................................... 34 Chapter Four. Evaluation of Thatcher’s Reforms .............................................................................. 37 4.1 Effects of Thatcher’s Reforms ................................................................................................... 37 4.2 Problems of Thatcher’s Reforms ............................................................................................... 39 4.3 Intrinsic Characteristics of Thatcher’s reforms.......................................................................... 42 Conclusion.............................................................................................................................................. 46 Bibliography........................................................................................................................................... 48 v Introduction Her Majesty’s Civil Service, also known as the Home Civil Service, holds an extremely important role in the entire Western civil service system, with its successful model being imitated by many other countries. It is also one of the systems that Britain take full pride in, as quoted from Margaret Thatcher—the former Prime Minister of Britain whose fame rode the whirlwind in the world political arena in the 1980’s—who wrote in her memoir The Downing Street Years that “British Home Civil Service is absolutely professional. It enables the efficient operation of the Government” 1 .Thus, it is of enormous significance to learn and draw lessons from the reforms for the Home Civil Service and apply them in China’s modern civil service reform. Since British civil service reform has always been the focus of the world’s attention, its researches and studies from foreign scholars begin at a comparatively early age. For instance, the famous American scholar Dorman Bridgman Eaton 2 published Civil Service in Great Britain in 1880 and P. G. Cocker published Contemporary British Politics and Government in 1994, both of whom have given quite a comprehensive description of the British civil service. Domestically, studies on British civil service commences since the Revolution of 1911; however, monographs on its systematic exploration find themselves scarce in the 1980’s, with examples such as Administrative Organization and Civil Service System in Britain (《英国行政机构和文官制度》) written by Gong Xiangrui(龚祥瑞), and Western Civil Service System (《西方文官系统》) by Yang Bokui(杨伯揆). In the 1990’s, domestic books on British civil service include Contemporary Civil Service System in Capitalist Countries (《当代资本主义国家的文官制度》) by Zhou Kaimin(周凯敏); Comparison on the World’s Civil Service Systems (《世界各国公务员制度比较》) by Xu Zhenhuan(徐振寰); and Comparison on Civil Service Systems(《公务员制度比较》) by Tan Gongrong(谭功荣), etc.. Most of the works feature a comprehensive coverage about the history of the British Civil Service Reforms, demonstrating authors’ selective emphasis on the analysis and comparison of different types of civil service systems or diverse systems 1 2 Thatcher, Margaret. The Downing Street Years [M]. London: Harper-Collins, 1993. p.78. Dorman Bridgeman Eaton: (27th, June, 1823 – 23rd, December, 1899), instrumental in American federal Civil Service reform, and an American lawyer. 1 within a certain civil service. However, few have fleshed out the in-depth exploration on the radical and enduring civil service reforms during the Margaret Thatcher Government. Though much attention has been drawn to the study on Margaret Thatcher’s personal charm, her political reforms, and the privatization, little is paid to her civil service reform in terms of its background, impetus and the problems within the reform. Thus, in this paper, the author would try to explore in that regard, and what’s more important, the function of the ideological origins in shaping Thatcher’s reforms. In this paper, two approaches are adopted regarding its structure and conception. To begin with, a historical approach is employed for the introduction on the history and background of British civil service reforms in chronological order, with the focus on the introduction of reform measures taken by Thatcher Government. Second, a comparative method is applied so as to conduct the analysis on the ideological origins of the reforms within a horizontal framework and thus utilize the rules in the development of China’s civil service system after discerning thoroughly the similarities and distinctions. British civil service system is a major component of British administrative system, with its formation and development being the result brought by the changes in the administrative system. Historically, British administrative system has undergone three major changes: the first change happened in the 11th century during the Norman Conquest when William I set up a centralized feudal society by introducing into British the administrative system from the European continent, as a consequence, the King and his family became the country’s governors with all the aristocrats being the king’s vassal. Thus, the eradication of the original feudal separatist system enabled the centralization and institutionalization of the country’s administrative system under the king’s centralized control. The second change happened in the 1530’s during Tudor Revolution in Government when Henry VIII abolished the administrative system which was oriented by Royal and aristocratic family, and replaced it with various ministries centered by administrative bureaucrat, thus weakening the power of the feudal aristocracy while further strengthening the king’s control over the state administration. This revolution symbolized the beginning of the modernization and specialization of the administration of the United Kingdom. 2 The third change happened in the 19th century, initiated by the Parliamentary Reform in 1832, unveiling modernization process for British political and administrative systems. The administrative system reform during the Queen Victoria Era not only swept away the remnants left over from the middle Ages, putting an end to the Crown’s control over the country’s administration, but also set up a new administrative system in which government ministries should be responsible to the Parliament. Thus, along with the emergence of modern election system, modern political party system and cabinet system, the modern civil service system came into being as the situation required, with its indication being the proposal and implementation of Northcote-Trevelyan Report in 1854 on civil service system reform. 3 Chapter One. Background to Margaret Thatcher’s Civil Service Reforms 1.1 A Brief History of Home Civil Service Reforms 1.1.1Northcote-Trevelyan Report The civil service system is defined as the systematical regulation formed in the history regarding the classification, examination, recruitment, assessment, reward and punishment, treatment, training, promotion, reassignment, dismissal and retirement of civil servants. As a modern personnel management system, the British civil service evolves in the process of surmounting the drawbacks and maladies of the “Patronage System” 3 (also known as “Spoils System”, an informal practice where a political party, after winning an election, gives government jobs to its voters as a reward for working toward victory, and as an incentive to keep working for the party). In accordance with conventional practice, the civil servants have always been recommended and appointed within the circle of powerful families. By the year 1854, the civil service system had still been a by-product of political “Patronage System” which featured feudal nature. However, in the mid-19th century after the realization of British Industrial Revolution, the Government's socio-economic management functions became more and more important as industrialization progressed, while the original civil service could not guarantee the normal exertion of government functions. Thus, to get rid of the drawbacks of traditional civil service system and to set up a clean and efficient administrative system became the top priority. Meanwhile, the Industrial Revolution caused significant changes in Britain’s social structure. For one thing, the industrial bourgeoisie became the protagonist of the socio-economic arena, and began to take dominating roles in state authorities, challenging the traditional civil service system. Thus, in 1854, under strong request of the industrial bourgeoisie and the Finance Minister William Gladstone, two officers of Ministry of Finance Northcote and Trevelyan drafted the famous Northcote-Trevelyan Report, putting 3 Retrieved on 3rd, October, 2008 from http://en.wikipedia.org/wiki/Patronage_system. 4 forward the principal objectives of their recommendations for the permanent civil service reform: 1. To provide, by a proper system of examination, the public service with a thoroughly efficient class of men. 2. To encourage industry and foster merit, by teaching all public servants to look forward to promotion according to their deserts, and to expect the highest prize in the service if they can qualify themselves for it. 3. To mitigate the evils which result from the fragmentary character of the service, and to introduce unity by placing the first appointments upon an uniform footing; opening the way to the promotion of public officers to staff appointments in other departments than their own; and introducing into the lower ranks a body of men (supplementary clerks) whose services may be made available at any time in any office whatever 4 . Northcote-Trevelyan Report served as a watershed in the development of British civil service system. The Northcote-Trevelyan model remained essentially stable for the next one hundred years. This was a tribute to its success in removing corruption; delivering public services (even under the stress of two world wars); and responding effectively to political changes. Its principle on civil service examinations was soon implemented. A Civil Service Commission was accordingly set up in 1855 to oversee open recruitment and end patronage. In 1859, Superannuation Act provided specific provisions on the qualifications of civil servants that only holders of certificates issued by the Civil Service Commission were eligible to receive pension. In 1870, the Civil Service Commission instructed that ministries with approval by their ministers (except the Ministry of the Interior and the Ministry of Foreign Affairs) should implement a civil service recruitment which was open to all society. And in 1914, civil service recruitment of all ministries carried out a uniform examination, except for the Ministry of Foreign Affairs which could make separate arrangements under particular circumstances. After World War I, the government made such adjustments on civil service system as to appoint the Permanent Secretary under Ministry of Finance to be the highest civil servant responsible for the leadership of all the civil servants; and in 1943, the civil 4 Northcote, Stafford H., Trevelyan, C. E.. Report on the Organization of the Permanent Civil Service [R]. London: Stationery Office, 1853. 5 servants under Ministry of Foreign Affairs were marked out into direct management of the government. To sum up, the 1855-1870 reform initiated with Northcote-Trevelyan Report basically succeeded in abolishing maladies such as corruption, confusion and inefficiency of the old civil service system, while establishing basic principles of modern civil service system which included examination, permanent service, neutrality and generalists. This reform marked the formal establishment of modern civil service system and provided for the subsequent reforms with basic values—probity and efficiency. 1.1.2 Fulton Report In the 1960’s, Britain’s international status underwent fundamental changes. The British Empire collapsed and its diplomatic influence had decreased significantly since the withdrawal from east Suez in 1956, reducing the nation to a status featuring second-rate power. Domestically, the Ministry of Finance was exposed to criticism both within and outside the government, due to its incapacity to achieve the expected goals on civil service management. Thus, in order to cope with the new situation both home and abroad, the Prime Minister Harold Wilson announced on 8th February 1966 in the House of Commons the appointment of a Committee on the Civil Service (which became known as the Fulton Committee) “to examine the structure, recruitment and management, including training, of the Home Civil Service, and to make recommendations” 5 . In 1968, the publication of Fulton Report as a command paper began the journey of a second eye-catching civil service system reform within a century. According to Fulton Report, the Fulton Committee stated that the civil service of the day was fundamentally the product of the 19th century philosophy produced by the Northcote-Trevelyan Report; whereas the tasks the civil service faced were those of the 20th century, which was inadequate to meet those tasks. Thus it advanced a series of recommendations, three important ones of which were: to restructure civil service system by implementing a unified grading system for all staff so as to facilitate the management and operation; to strengthen college training for civil servants by creating a Civil Service 5 Cabinet Office. The Civil Service: Continuity and Change [M]. London: Stationery Office, 1994. p.13. 6 College; and to deprive the Treasury of responsibilities regarding recruitment policies and management; and to establish a new government department with personnel responsibilities specifically for the civil service. Basically, these proposals were implemented which centered on improving the quality of management in the civil service in order to increase efficiency and economy; however, whether through lack of political will, or through passive resistance by a mandarin which the report had suggested were “amateurs”, Fulton failed. The Civil Service College equipped generalists with additional skills, but did not turn them into qualified professionals. Recruits to the fast stream self-selected, with the universities of Oxford and Cambridge still producing a large majority of successful candidates, since the system continued to favor the tutorial system at Oxbridge. The younger mandarins found excuses to avoid managerial jobs in favor of the more prestigious policy postings. Besides, Fulton Report failed to address problems such as the excessive expansion and inefficiency within the civil service system; therefore resulted in few remarkable changes on the management and operation of civil service system. Throughout history of Britain’s modern civil service reforms, it is found that the 1855-1870 reform brings about revolutionary changes by clearing the remnants of feudal privileges and establishing principles such as examination, permanent service, neutrality and generalist; by abolishing maladies such as corruption, confusion and inefficiency of the old civil service system and creating a new modern civil service system with probity and efficiency, all of which help Britain adapt to capitalist development after the industrial revolution. Whereas the second reform, in obedience to the tenet of probity and efficiency within the framework of civil service system which is established after the 1855-1870 reform, focuses on improving the quality of the civil service, enhancing the professionalization of the civil service so as to equip civil servants with modern technology knowledge and management skills, and increasing their work efficiency to overcome bureaucracy and adapt to the requirements which the technological era bestows onto the civil service. In this sense, the second reform is the legacy and development of the 1855-1870 reform. 7 1.2 Background to Thatcher’s Reforms Unquestionably, the civil service system has played an essential role in maintaining continuity of government administration; recruiting talents; enhancing administrative efficiency; guaranteeing openness, justice and fairness; as well as promoting socio-economic development. However, with Britain’s transformation from an Industrial Society to a Post Industrial Society and the advent of the globalization era since the latter half of the 20th century, the growing limitations of the civil service system exposed themselves, failing to meet the needs of the new era. 1.2.1 Inherent Problems within the Civil Service System First, the ever enlarging scale of civil service resulted in overstaffed institutions. The number of civil servants had grown ceaselessly since its establishment in the mid-19th century. During the years from 1881 to 1914 featuring a rapid expansion of the British Empire, the government institutions expanded to such a point that the total number of civil servants increased by more than five times during the 33 years, and to a total of more than 710,000 in 1943 6 . Although there was a slight reduction in the size of the civil service after World War II, the permanent tenure character of civil service, that is, once recruited, the civil servants would secure the position permanently as long as no fault was made, caused not only bloated civil service organizations, but also inefficient government performance since the civil servants appointed during the war were incompetent to manage the war-torn society. Meanwhile, under the guidance of Keynesian economics, the post-war governments unanimously agreed that “Government functions must be expanded - this is the only practical approach.” 7 (政府机能必须扩大——这是唯一切实的办法。) To this end, policies and systems were introduced on the expansion of the national intervention with economic and social life and creation of a welfare state, which inevitably gave rise to the expansion of government functions. As a result, public departments were set up one after 6 7 Butcher, Tony. The Civil Service Today [M]. London: Basil Blackwell, 1993. p.48. 约翰·梅纳德·凯恩斯.《就业、利息和货币通论》(高鸿业译)[M]. 北京:商务印书馆,1999. p.322. 8 another, with some even being regarded as a remedial measure to economic mismanagement. The inevitable outcome was that “the public sector expanded rapidly during the recession at the expense of the private sector while failing to come down during the economic boom period, winding up with a vicious circle of government expansion and the economic failure. The number of civil servants had reached its highest point after the war at 732,000, which unavoidably led to bloated civil service organizations.” 8 (公共部门 在萧条时期以牺牲私营部门为代价急剧扩张,但在经济迅速增长时期又不缩减,结果 是造成政府扩张和经济失败的恶性循环。文官的数量也达到战后最高点 73.2 万人, 这必然导致了文官组织机构臃肿。) Besides, bloated and overstaffed civil service institutions also imposed magnificent difficulties because of the redundant administrative expenditure and the inefficient performance which went against the expectations from the public as well as the government. Second, generalists were no longer adequate for the professional tasks. Being a fundamental feature of British civil service system, the idea of generalist education was reflected as early as in 1854 when Macaulay9 drafted the Macaulay Report, advocating that the British civil service examination should focus on general knowledge and ability referring to the curriculum of two well-known universities, namely, Oxford and Cambridge. At the same time, the Northcote-Trevelyan Report further provided that the civil service should be divided into two categories, with recruitment based on competitive examination while in the form of different tests: high-level positions must require a university degree, while lower-level positions with secondary education. The above two reports demonstrated the generalist character of British civil service, paving the foundation for the later phenomenon that the senior civil servants were mainly graduates from Oxford and Cambridge University. It was true that due to the relatively small government scale and its limited functions, civil servants in the mid-19th century were not necessary to be equipped with professional expertise; in fact, their generalist background helped enhance the comprehensive ability and facilitate social development at the time. However, the sixties and the seventies of the twentieth century witnessed a total shift for the British civil service boasting dramatic 8 周志忍.《当代国外行政改革比较研究》[M]. 北京:国家行政学院出版社,1999. p.57. Baron Macaulay: (25th, October, 1800 – 28th, December, 1859), a nineteenth-century British poet, historian and Whig politician. 9 9 changes in the objective environment, where new fields of public policies (such as environmental protection, technological development, etc.) called for an unprecedented degree of public concern; economic development was unstable featuring severe stagflation crisis; social structure underwent major transformation; and the middle class turned into main body of the society. These changes implied further expansion of government functions, both manifested in the new management areas (such as environmental protection, organized scientific and technological development, etc.), and in the new service functions (such as establishment of economy plan and assistance for enterprises to improve their international competitiveness). These newly generated social affairs starved for prompt settlement from professionals, which contradicted the fact that the majority of civil servants were generalists. It had been an increasing serious prejudice that during the recruitment of modern British civil service, the influence of generalist principle was still difficult to shake off. Third, the rigid bureaucratic structure brought about corruptive bureaucracy. In essence, the organizational structure of British civil service system featured a Weberian character, namely, a strict hierarchy. In this hierarchical structure, “each ministry was firmly controlled by a permanent secretary, who did not need to struggle to remove the obstacles and constrains posed as results of conflicts between cabinet ministers, central and local administrative officers and senior officials.” 10 (每一个部由一位常务次官牢牢控 制,常务次官可经历几届部长,并且不必为清除由内阁部长、中央与地方行政官员、 高级官员的冲突所制造的障碍和束缚而斗争。) And the permanent tenure system enabled civil servants to climb upon the hierarchical ladder step by step till retirement, no matter how effective of the work or how capable of the civil servant. For example, “in 1972, about 72% of the total civil servants were permanent employees and in 1977 the proportion among principal officer reached up to 75%, and 25% of the executive officials were senior staff with more than 20 years of service.” 11 (1972 年约有 72%的文官是终身共 职。1977 年在特等执行官中有 75%,在执行官中有 25%是服务满 20 年以上的资深人 员。) Long term of engagement in corresponding administrative posts molded the civil 10 帕特里夏·英格拉姆.《西方国家行政改革述评》(国家行政学院国际合作交流部编译局)[M]. 北京:国家行 政学院出版社,1998. p.237. 11 龚祥瑞.《英国行政机构和文官制度》[M]. 北京:人民出版社,1983. p.72. 10