Review article
POLISH AND GERMAN CONSTITUTIONAL JURISPRUDENCE ON MATTERS OF EUROPEAN COMMUNITY LAW: A COMPARISON OF THE CONSTITUTIONAL COURTS’ APPROACHES
Sven Höbel
Abstract
Germany and Poland are the two largest EU members in Central Europe.
Although they are neighbouring countries, their historical situation and perspectives,
and thus their expectations and motivations regarding EU membership, differ greatly.
The two states’ legal systems, on the other hand, are largely similar. This article aims to
compare how the two countries’ constitutional preconditions determine how their
constitutional courts approach the integration of Community law. It also aims to point
out similarities and differences between the courts’ approaches. Furthermore, it seeks to
illuminate the difficult relationship between constitutional courts and the European
Court of Justice and indicate possible ways of mitigating these theoretical and practical
difficulties in the future.
Keywords
Hrčak ID:
28571
URI
Publication date:
2.11.2007.
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