A new book this week 'Countering Terrorism in Britain and France’ by Dr Frank Foley, has had some coverage here:
He, too, had long been baffled by the varied approaches. And one thing that has become clear from his research is that the reason has little to do with the European court and much more to do with the different recent histories of the two countries and how their institutions have developed.
Link to an article focussing on the UK's inability to deport Abu Qatada:http://www.telegraph.co.uk/news/ukne...h-jihadis.html

An ICSR podcast:http://icsr.info/2013/05/icsr-semina...in-and-france/

Three years ago I posted the thread 'Londonistan: Muslim communities in France & UK:
Largely for historical reasons IMHO neither the UK or the USA closely look at how France has responded to the violent Jihad and Muslim communities. Plus of course the language barrier.
Link:http://council.smallwarsjournal.com/...ad.php?t=16376