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The discussion on the emergence of global administrative law is centered around the question: "Is it law?" and problems of accountability. This is a narrow perspective which ignores the autonomy of the administrative "internal law" generated by administrative agencies themselves. This is shown for the evolution of domestic administrative law in the 19 th century and its transformations in the 20 th century. Domestic administrative law is only to a much lesser extent a product of courts ordoi:10.2139/ssrn.1792062 fatcat:55ldivvgn5ehdcumgmotwwyqku