Buffalo Law Review

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An abbreviated version of this paper was presented by the author at a meeting of the Society of Comparative Law in Hamburg, Germany, on September 21, 1973. The full text, printed here, appears also in the "Arbeiten zur Rechtsvergleichung", published by the Society in Germany. While the paper was prepared for a foreign audience, its unitary approach to the full range of private litigation in the public interest—class actions, shareholders' derivative suits and public interest actions—will be of considerable interest to American readers. The Buffalo Law Review gratefully acknowledges the cooperation of the Society of Comparative Law in arranging publication in the United States.