Comparative Overview of European Systems of Constitutional Justice

Abstract

There are various models of constitutional reviews described in the academic literature, such as, American diffuse model, Austrian, German or French models. European constitutional courts or other organs of constitutional review do not easily fit into such a classification. Features of the various constitutional courts and equivalent bodies in Europe are quite complex and it would be hard to find even two courts, which have the same characteristics.

The author of present article proposes three criteria to distinguish courts: composition, types of jurisdiction, effects of the decisions. According to these criteria, Mr. Dürr discusses European systems of constitutional review and provides interesting conclusions about them.