Locus Standi and distrust of the public administration. A comparison of three models

The paper examines the connection that exists in three specific legalordersbetween theregulation oflocusstandiinthepublicinterest inadministrative litigations, and the confidence that the society and the institutions place in the role and authoritativeness of the public administration. To this end, after briefly addressing the concept of ‘Counter-Democracy’, focus is turned first to the current debate regarding locus standi in the public interests in Germany and then to the situation in Italy. This analysis aims, on the one hand, to aid understanding of the reasons underlying the differences that can be found between these two legal systems and, on theotherhand,toexplain the tensions that are present in the third model, that of the European Union, which affect locus standi for environmental matters in relation to the Aahrus Convention