A European Perspective
Comparing jurisdictions is not simple; it can even be impossible unless one chooses a rather specific perspective from which to analyse the situations being compared. Looking at the House of Lords from the point of view of continental European legal systems requires the identification of a link between the various European constitutional courts and the highest British court. Today this link can be found in the overriding duty to respect the rights accorded by the European Convention on Human Rights and Fundamental Freedoms. There is, then, something in common between the various courts: it takes the form of the need to adhere to Convention rights. In this context, this chapter distinguishes between the ways in which these rights are integrated into the different constitutional systems and the ways in which they are interpreted.
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