. -- proportionality ; comparative law ; Germany ; Uncertainty ; margin of appreciation ; constitutional law ; Canada ; South Africa …. This contribution has a twofold aim. First, it tries to show that legal reasoning in constitutional law is often based on … argument, I will discuss decisions of different jurisdictions, including the United States, Canada, Germany and South Africa …

systems in Japan and Germany; second, the access to justice in both countries; and finally, the role of courts in shaping the … role. But on the other hand, the Court does assume a very active role in the broad field of civil law where it rendered a … is based on how access to justice is organized. In Germany we see an open market for legal talent and an affirmative …