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This is a comparative approach to examining the effect of different constitutional and legal traditions on privatization.;The authors focus on privatization in the UK and France. They suggest that the British Government was remarkably free from constitutional limitation, whereas in France the written constitution imposed important restrictions on the scope of privatization and on the arrangements for the pricing of shares. They go on to describe the links created between privatized enterprises and government by devices such as golden shares and analyze the constrains of competition law and the regulatory arrangements in Britain. They also compare the British regulatory agencies with those in the United States, looking in particular at the way in whch the influence of Federal and State constitutions has led to the incorporation of significant elements of openness in decision-making procedures.;This detailed analysis of the effect of legal constraints on economic policy adds a constitutional dimension to what has primarily been seen as an economic issue, and will make a contribution to current debates in political studies.