Through a comparative analysis of England, the EU, and the US, this book considers legal responses to delegation of governmental power to private parties. Although private delegation has the potential to enhance the efficiency and effectiveness of governance, it creates risks to democracy, accountability, and human rights. Any legal controls must therefore respond to the challenge of enhancing the potential effectiveness of private delegation, whilst minimizing the risks. The legal responses of the three jurisdictions to private delegation are categorized in a two-fold and functional way: responses which impose controls on the delegation of governmental power, and responses which impose controls on the private parties to which governmental power has been delegated. The controls imposed by constitutional law, administrative law, regulatory law, and private law are assessed. Three goals are pursued. First, the legal mechanisms which are used to control delegation in the three jurisdictions are reviewed and the relationship between them is illustrated. The challenge of private delegation is complex, requiring a multifaceted response from a number of different legal disciplines. No one source of legal control is in itself adequate to respond to the challenge. Second, those features of each legal system which affect the way in which it controls private delegation are considered. Third, Donnelly demonstrates how at present, the response of all three jurisdictions to private delegation is inadequate, albeit to differing degrees, and comments on how the law could be used to control the conditions under which private delegation takes place. A much greater awareness of the risks of private delegation and a greater sense of responsibility on the part of the judiciary are required if these legal systems are to respond effective