Ewolucja modelu kontroli konstytucyjności prawa w Wielkiej Brytanii
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In the past thirty years certain Commonwealth countries developed a set of instruments of judicial review which can be seen as an alternative to the mutually exclusive models of constitutionalism: the sovereignty of parliament and the judicial supremacy. These institutional developments thus gave the opportunity to conceptualize a new, so -called mixed or weak -form model of judicial review. In the United Kingdom these changes were brought by the introduction of Human Rights Act in 1998. Yet, the analysis of four past proposals for a codified UK constitution show that further developments, even the adoption of the American model of judicial supremacy, are possible if the constitutional moment was to come.
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