JUDICIAL REVIEW OF LEGISLATIONS : A COMPARATIVE STUDY OF AMERICAN AND GERMAN LEGAL SYSTEM

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พิชชาพร สุทธิรอด

Abstract

There are many differences between American and German judicial review due to distinct historical concept and conception of some legal principles. However, by comparing concrete judicial review which exist in both systems, it was found that they were surprisingly similar. This lead to a conclusion that American and German judicial review share the same functions, to limit legislative power and to protect rights of the people.

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