Inter Courts Dialogue and Multilevel Protection in Italy, Germany and France: a Comparative Perspective

Abstract

The paper examines the applicability of the European Convention on Human Rights and the Charter of Fundamental Rights of the European Union within three legal systems: Italy, France, and Germany. Adopting a comparative perspective, it highlights the different ways in which these instruments are applied in domestic contexts and analyses the judicial dialogue on fundamental rights among ordinary courts, constitutional courts, and European courts.