The suspension, prosecution and dismissal of the president of Romania and of other heads of state from European Union
| Author | Varvara Licuta Coman - Minodora-Ioana Rusu-Balan - Ion Rusu - Angelica Chirila |
| Position | Senior Lecturer, PhD, Public and Private Law Department, Law Faculty, 'Danubius' University of Galati, Romania. - Senior Lecturer, PhD in progress, Law Department, Law Faculty, 'Danubius' University of Galati, Romania. - Assistant Professor, PhD in progress, Law Department, Law Faculty, 'Danubius' University of Galati, Romania. - Legal ... |
| Pages | 1-12 |
1
THE SUSPENSION, PROSECUTION AND
DISMISSAL OF THE PRESIDENT OF ROMANIA AND OF OTHER
HEADS OF STATE FROM EUROPEAN UNION
Ion Rusu
1)
Angelica Chirilă
2)
Varvara LicuŃa Coman
3)
Minodora-Ioana Rusu-Balan
4)
Abstract
This study examines a critical view of a particularly sensitive topic and
briefly discussed in the literature, namely: the responsibility of the President of
Romania. Given the complexity of this theme, the research focuses on the severe
analysis of the constitutional standards relating to political and legal
responsibility of the Institution of the President of Romania in the light of serious
violations of the Constitution. The analysis also seeks scientific interpretation of
the legal phrases "grave acts” which violate the constitutional stipulations" and
"high treason", by identifying specifically those actions that can be classified as
"grave", and also those that can meet the elements of an act of "high treason".
The whole issue concerns the comparative analysis with the fundamental laws of
some states with traditional democratic regimes. The analysis highlights the need
for supplementing and amending some constitutional rules on the subject
examined from the perspective of more accurate evaluation and of clear
demarcation of Constitution violations, which can be interpreted as grave or
others of high treason that can be imputed to the President.
Keywords: Constitution; grave act; high treason
1. Introduction
The constitutions of democratic regimes states recognized throughout the
world provide a series of depositions relating to political and/or legal
1)
Senior Lecturer, PhD, Public and Private Law Dep artment, Law Faculty, „Danubius”
University of Galati, Romania.
2)
Senior Lecturer, PhD in progress, Law Department, Law Faculty, „Danubius” University of
Galati, Romania.
3)
Assistant Pro fessor, PhD in progress, Law Department, Law Faculty, „Danubius”
University of Galati, Romania.
4)
Legal Counselor, S.C.SOTIREX, Bacau, Romania.
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responsibility of their leaders. Naturally, the general rule imposed by a series of
objective commands aims at ensuring the governance is: the head of state enjoys
the jurisdictional immunity.
This paper presents a current perspective, the practical possibilities, in which
the President of Romania may be suspended, prosecuted or dismissed, in
situations where the President commits a series of serious offenses.
The subject, particularly sensitive in the socio-political context of our country,
has not been yet analyzed, as far as we know, by any other authors, but it is still
analyzed by us tangentially, in two other papers published in two journals in Romania
(The Relations of the President with the parliament and government. Critical
remarks, in Transylvanian Review of Administrative Sciences. No. 1/2010 and
Discussions on the constitutional rules regarding the appointment of the candidate
for prime minister by the President of Romania, in Dreptul Journal no. 12/2008).
Without a doubt, taking such extreme measures was determined by
committing serious violations of the Constitution of Romania by the President of
Romania, deeds that must be first established by the Parliament and subsequently
assessed (where applicable) by the High Court of Cassation and Justice.
In this context, according to the stipulations of the Constitution, we may say
that the responsibility of the President of Romania may take two forms, namely,
political and legal responsibility. In researching the two forms of responsibility,
we follow two aspects: on one hand the seriousness of the offenses committed by
the President, and on the other hand, the jurisdiction over the final decisions,
which belongs to different institutions.
The political responsibility refers to two categories of measures which have a
chronological order that is: the suspension and dismissal.
The suspension falls within the exclusive competence of the Parliament, and it
is the first phase of political responsibility, then the dismissal from the office, the
second phase, is for the voters, that will decide within the referendum.
Regarding the liability, the second form of the President’s responsibility can
only happen when Romania's President is guilty of “high treason”. We consider
here only the criminal liability, which is the most severe form of legal
responsibility, than any other form.
On the need to provide in the constitution the political and legal sanctions for the
President of Romania, we express our view that they are absolutely necessary in
terms of occurrence of actions or attitudes that endanger the democracy and the state
law, especially by deviations of totalitarianism and consequently of dictatorship.
Moreover, the conducted examination shows that the political or legal
responsibility of the heads of state is planned by the fundamental laws of other
states, making an exception to this rule the states with constitutional monarchical
regimes, of tradition from Europe.
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2. The suspension of the President
After examining the constitutional institutions, we consider the role of the
Romanian Parliament, which is defined as “(...) the supreme representative body
of the Romanian people and the sole legislative authority of the country” [the
Constitution of the Romania, article 61 paragraph (1)].
The key role of the Parliament, results from the fact that the constitutional
provisions that govern the organization and functioning of the institution are laid
down in Chapter I of Title III suggestively called by the constituent legislator “the
Public Authorities”. Likewise, in the specialized literature it is presented this
view: “mentioning the Parliament in the first chapter highlights the importance of
this institution in the Romanian political system emphasizing practically its
priority in relation to other public authorities, including the President of
Romania” (Rusu, 2010, p. 193-214).
This interpretation, according to the constitutional provisions, was supported
by other authors in our doctrine, who mentioned that “the Constituent Assembly of
Romania has given the Parliament, a traditional institution in democratic
countries, the first place among public authorities. This settlement of the
legislative power is the natural result of the rational order of institutions whose
form of government is the republic, and also the representative feature of this
authority, of the ancient roots of the institution in state and political practice”
(Vida in Constantinescu et. al., 1992, p. 133).
Given this vital role within the state, it is natural for the Parliament to have
the competence and ability to suspend the President if he committed grave acts.
Thus, as the supreme organ of the Romanian people, the Parliament is the only
institution that can decide the liability of the President, even if, as senators and
MPs, it has the same legitimacy, being elected by universal, equal, direct, secret
and freely expressed vote [Constitution, article 81 (1)]. This view is supported in
the literature, which states that” (...) as supreme body, the Parliament may held
liable the President of Romania, even if it enjoys a similar legitimacy to the
Parliament, being elected as the MPs by universal, equal, direct, secret and freely
expressed vote” (Constantinescu in Constantinescu et. al., 2004, p. 119).
According to constitutional provisions, the President of Romania may be
suspended by the Chamber of Deputies and Senate in joint session, by a majority
vote of Deputies and Senators, after consulting the Constitutional Court, only
when there are committed grave acts that violate the Constitution" [article 95
paragraph (1) of the Constitution].
From a procedural perspective, the Constitution provides that the proposal for
suspension may be initiated by at least one third of the deputies and senators.
Although the text does not use the term “total” only “number”, from the
interpretation of the constitutional depositions, it results that it cannot be about the
total number of deputies and senators.
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This view we have supported also in another paper showing that “the
interpretation of these rules leads to the conclusion that the third must come from
the total number of deputies and senators, that means that there are different
proportions at the level of the two Chambers, being important the total number of
parliamentarians. This does not exclude the possibility of one third in the
Chamber of Deputies and in the Senate” (Rusu, 2010, p. 193-214).
If the proposal for suspension has been approved, within 30 days, it will be
organized a referendum on the dismissal of President [Constitution of Romania
article 95 paragraph (3)].
Given the above the mentioned constitutional provisions, we are justified to
wonder which are the serious acts established by the Parliament according to
which the Constitution is violated. Please note that currently, that in the
Constitution and other laws, there are no legal rules to incriminate certain acts
committed solely by the President of Romania.
So, the Parliament will have the role of determining which are the acts
committed by the President and if they can be considered as serious violations of
the Constitution.
Taking into account the difficulties that may arise in assessing the gravity of
the acts committed by the President, the Constitution provides in article 95
paragraph (1) and article 146 point h) that the Parliament is obliged to consult the
Constitutional Court.
Using the legal phrase “serious acts”, it leads to the conclusion that they (the
serious acts) do not have to be offenses. So, it is serious enough that by these acts
it is violated the Constitution.
According to our analysis, we consider that the most important and difficult
task of the Parliament is to determine the gravity of the acts committed by the
President, the suspension procedure is not likely to cause trouble.
We believe that the assessment of offenses as being serious, must be made in
the context of their commission, in relation to further or immediate consequences
that may arise. Certain acts committed in the context of an economic crisis or
political instability can have serious consequences, for the same acts committed in
a situation of political and economic normalcy.
Another category of acts which may be interpreted as serious regards the way
in which the President intends to apply the constitutional rules, in his relation with
the Parliament or the Government.
Another act that we consider to be serious, is the action of the President to
dissolve the Parliament, in conditions of economic or political crisis. Thus, under
the provisions of article 89 paragraph (1) of the Constitution, “after consulting the
Presidents of both Chambers and the leaders of parliamentary groups, the
President of Romania may dissolve the Parliament if he did not granted the vote
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of confidence in order to form a government within 60 days from the first request
and only after the rejection of at least two requests for investiture”.
From the assessment of the mentioned constitutional norm, it results that
dissolving the Parliament represents for the President a variant of solving the
political crisis, an option, not compulsory. In this context, we consider that the
dissolution of the Parliament in a situation of serious economic or political crisis,
that can lead to causing a general protest from political parties or citizens and thus
endangering the constitutional legal order.
Given the examined constitutional law rules, we consider that, in order to
suspend the President, the Parliament should set specifically the commitment of
grave acts by which there are violated the constitutional provisions, such as those
explained above. The acts by which the President violates the constitutional
norms, but cannot be interpreted as serious within the meaning of article 95
paragraph (1) of the Constitution, it cannot lead to suspension.
3. Prosecuting the President
Regarding the liability of the President, that is the criminal liability, according
to the Constitution, it can take place only if it is established that he is guilty of
high treason.
Thus, under the Constitution, the Chamber of Deputies and the Senate, in
joint session with the votes of at least two thirds of the deputies and senators may
decide to indict the President of Romania for high treason [the Constitution, Art.
96 paragraph (1)].
Paragraph (2) of the same article provides that the proposed prosecution may
be initiated by a majority of deputies and senators and, without further delay, the
Romanian President must be informed in order to give explanations about the
accusations.
Paragraph (3) provides that from the date of the prosecuting until the
dismissal, the President will be rightfully suspended.
Paragraph (4) provides the court jurisdiction, which belongs to the High Court
of Cassation and Justice, and the fact that the President is rightfully dismissed at
the date of remaining definitive the sentencing decision.
Prosecuting is the most serious measure that can be imposed by the
Parliament against the President of Romania.
According to our assessment of the mentioned constitutional rules, it is
necessary to clarify the interpretation of some legal phrase, given that the
literature has not made yet this interpretation.
Thus, a first aspect envisages the legal interpretation of the expression “high
treason”. As it is well known, both in the current Penal Code and special laws
with criminal depositions, it is not incriminated such offense (an offense with this
name).
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In this context, with no Constitutional Court's interpretation on a particular
case (it is not desirable) and only a few interpretations in the specialized literature,
we would naturally ask the question, what did the legislator mean by the legal
phrase “high treason”?
In the previous work, we identified several possible actions that could be
assimilated to the President as acts of high treason, namely:
“– Politico-legal implications of that act, in terms of socio-economic and
political life;
– Causing a major political crisis with direct implications on the evolution or
devolution of the national economy, public order and safety or state stability;
– Causing serious state prejudices;
– Betrayal of national interests or committing offenses against state security;
and – Other related issues that lead to the conclusion that the act committed by the
President is very serious” (Rusu, 2010, p. 193-214).
In addition to the above facts, we believe that there can be interpreted as acts
of high treason committed by the President, the following:
– Instigating people against a certain social category, this resulted in a serious
disruption of constitutional order and brought serious damage on the social
category;
– Some crime provided under Title I of the Special Part of the Criminal Code,
namely: treason (article 155 of the Penal Code) treason by helping the enemy
(article 156 of the Penal Code), treason by transmitting secrets (article 157 of the
Penal Code) disruption of state power (article 162 of the Penal Code) propaganda
in the favor of the totalitarian state (article 166 of the Criminal Code) etc.;
– Crime and corruption; and
– Action seeking to change the constitutional order.
No doubt that the scope of crimes which can be charged on the President, that
can be attributed as the legal phrase of high treason, it seems to be much larger,
their presentation is merely illustrative.
In the specialized literature, it was highlighted that “high treason should not
necessarily be framed in a text of the Penal Code, it must be accepted and defined
as the most serious breach of oath and interests of the people and the country, in
the exercise of presidential powers” (Vasilescu in, Constantinescu et. al., 1992, p.
193).
We express some reservations about this view, because in our opinion,
prosecuting for high treason involves, necessarily, at least committing a crime,
whether it is provided in the Criminal Code or in another special law with
criminal provisions.
The second issue that needs to be clarified is the legal interpretation of the
phrase “prosecution”, a specific activity only to the Parliament.
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Please note that the concept of “prosecuting” cannot be interpreted as criminal
activity undertaken by Parliament since the institution of state law, cannot
substitute for the prosecution bodies.
In these circumstances, if the Parliament no longer has the mentioned above
status, we legitimately wonder what is, practically, the work of prosecuting and
how can it be done effectively?
The specialized literature did not analyze this issue, although in our opinion,
under the current conditions it may be of great importance. Please note that the
existing constitutional rules make no reference to how to make this Parliament
activity work.
Given the above, we consider that the activity of prosecuting the President will be
achieved in practice by the parliament in three stages: successive, that is the proposal
of prosecution, which requires collecting the necessary evidence, the decision referral
for prosecution and informing the High Court of Cassation and Justice.
In the first stage, the proposal of prosecution may be initiated by the majority
of senators and deputies, in joint session. This proposal must be embodied in a
document, where there will be included the related evidence; they will be signed
and endorsed by the senators and deputies that initiated it. Although the
constitutional rules do not provide it, we believe that informing the President
involves sending the proposal accompanied by transcript of the hearing, and the
President will have to give explanations on the facts of the accusation.
After receiving the explanations and examining them, the Chamber of
Deputies and the Senate, in joint session with the votes of at least two thirds of
deputies and senators, may decide to prosecute the President for high treason.
The third and the last stage involve informing the High Court of Cassation
and Justice, which will proceed to trial the president for the charged acts.
Remember that, unlike the institution of suspension where it is asked the
Constitutional Court's advisory opinion, in case of prosecution it does not need
such advice.
The text of the Constitution states, in fact, that it is the only exception that a
physical entity can be judged without following the procedure for committing a
specific criminal offense.
4. The dismissal of the President
Depending on the President's political or legal liability, the dismissal of the
President can take two forms, namely the dismissal as a result of political or legal
responsibility.
The dismissal of the President as a result of political liability can take place
when, after his suspension from the office by the Parliament, following a
referendum, the voters approve the measure adopted by the Parliament.
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The dismissal, as a result of legal liability, may take place when the
President’s sentence, passed by the High Court of Cassation and Justice, is final.
Of course in both cases, the immediate effects will be: the Government will
organize an election within three months for another President.
5. Aspects of comparative law
5.1. The Constitution of the Italian Republic
Under the article 90 of the Constitution of the Italian Republic, “the president
is not liable for his committed acts while exercising his functions, except the act of
high treason or violating the Constitution”.
In case of attacking the Constitution, the President “is prosecuted by the
Parliament, in joint session, with the vote of the absolute majority of its members”
(Constitution of the Italian Republic, 1998, p. 43).
We note that the legal term of “high treason”, is mentioned in the Constitution
of the Italian Republic, without being defined explicitly (which is an element of
similarity with the Romanian Constitution).
Another element of similarity refers to the institutions called for
impeachment, i.e., the Chamber of Deputies and Senate in joint session.
Regarding the vote, it is sufficient an absolute majority from both the legislative
chambers. Unlike the Romanian Constitution, the jurisdiction of the court, under
the provisions of article 134, is of Constitutional Court, the procedure is very
different from that provided in our legislation.
5.2. Greek Constitution
The Greek Constitution provides that the President of the Republic shall not
be liable for the acts performed in exercising its functions, except for two
situations, namely when he commits an act of high treason or intentional violation
of the Constitution. Given this formulation, it is clear that the President may
respond to certain committed acts, not to the exercise its constitutional
attributions, but the prosecution is suspended until the expiry of his mandate. So
for committing some crimes that are not directly related to its constitutional
attributions, the President shall be criminally responsible, after his mandate
expires. Regarding the procedure of impeachment, it is similar to the Romanian
Constitution, meaning that the proposal of impeachment may be initiated by one
third of the members, and then it is submitted to the Chamber.
5.3. French Constitution
According to article 68 paragraph (1) of the Constitution of France concerning
the President responsible for high treason, the jurisdiction is of the High Court of
Justice, the court has jurisdiction to hear and judge “the government members if
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they would be accused of committing crimes or offenses or other facts of great
gravity for the state” (Ionescu, 2008, p. 380).
5.4. Portugal Constitution
Regarding the responsibility of the President, in the doctrine, it was
established that “it is interesting that the Basic Law has provided the criminal
responsibility for crimes committed by the President in exercising its functions,
and more. The power to institute proceedings is of the Republic Assembly under
the approval of the parliament by a vote of two thirds of the active in office
members. In the first case, the conviction sentence – handed down by Supreme
Court Justice – will automatically entail the dismissal of the president. In the
second case, the President will answer for his acts committed outside of his duties
after ending his mandate” (Ionescu, 2008, p. 396-397).
Note that the criminal responsibility of the President under the Constitution of
Portugal, is similar to that of the Greek Constitution.
5.5. The Constitution of Finland
Finland's Constitution provides that the President's responsibility, only in the
case of three categories of crimes committed, namely, treason, high treason or
crimes against humanity. In connection with the constitutional depositions on
criminal responsibility of the President of Finland, the literature has argued that
“if the Chancellor for Justice, the Parliamentary Ombudsman or the Government
believes that the President of the Republic shall be guilty of high treason, treason
or crimes committed against humanity, he will inform the Parliament. The
legislative body may, in such a case, decide the vote of three fourths of its
members, so that the charges are brought by the General Attorney before the
High Court of Indictment to be judged. During the trial, the head of state will be
suspended. In addition to the three categories of allegations, there are not
admitted other charges on the official documents issued by the President of the
Republic” (Ionescu, 2008, p. 433).
5.6. The Spanish Constitution
Under the article 56 paragraph 3 of the Spanish Constitution, “the king is
inviolable and he is not submitted to liability. His acts are always countersigned
as established by article 64, otherwise invalid, except the ones provided by article
65, paragraph 2” (The Spanish Constitution, 2003, p. 35)
Therefore, according to the interpretation of those mentioned constitutional
rules, the King cannot be held liable, not even for the acts signed by him, in this
case the responsibility becomes of the Prime Minister or his cabinet.
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At the same time in examining the king’s attributions, under the Constitution,
it results that they are almost insignificant, the government responsibility always
belongs to the Prime Minister and his cabinet.
5.7. Constitutional documents of the United Kingdom of Great Britain and
Northern Ireland
As the Spanish Constitution, the Constitutional Documents of the United
Kingdom of Great Britain and Northern Ireland do not provide the legal
responsibility of the King (Queen); it enjoys full immunity from criminal, civil or
political matters. All documents emanating from the king, under his constitutional
powers are countersigned by the Minister, which has to implement them, and he
assumes full responsibility for the way it is implemented and its legality.
5.8. The Belgian Constitution
Under article 88 of the Belgian Constitution, the king is inviolable, the
ministers, that countersign the documents emanating from the king, are legally
responsible. Also, the acts of the king, have no legal effect unless signed by the
minister who will implement them.
The summary presentation of certain provisions of the constitutions of some
states with recognized democratic regimes on political or legal responsibilities
that are incumbent on the heads of states, regardless their political regimes
(parliamentary, presidential or semi-presidential), clearly expresses two different
main orientations:
– A first orientation concerns the political and legal liability in case of
committing certain categories of offenses, usually known by the generic legal
term “high treason” for Romania, Italy, Greece, France and Finland (although in
the case of this country the Constitution provides two other categories of crime).
– The second orientation, including states such as Spain, the United Kingdom
of Great Britain and Northern Ireland and Belgium, where their constitutions
expressly provide that the king's person is inviolable, so he cannot be held for
legal or political liability.
A special case is presented by the Constitution of Portugal, where it is stated
that the President may be responsible for the crimes committed in the exercise of
his duties and also for other crimes, which have no connection with the exercise
of his powers. The essential difference lies in the procedure of liability, in the first
case the liability may intervene in the exercise of its function with the necessary
consequences, and in the second case, the liability will occur after the mandate.
So at the beginning of the third millennium, we cannot talk about a
constitutional regulatory unit in Europe, on the political and legal responsibility
for the ruler of a state in the case of committing grave acts, which violates
seriously the constitutional norms. However, note that in some states the
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constitutional rules on political and/or legal responsibility of the head of state are
similar.
6. Conclusions
The issue of liability of the President in terms of committing grave acts that
violate some legal rules or endangering the constitutional order, is topical and we
believe that it should be of serious concern, as theorists of constitutional law and
of political world or of the civil society.
Despite its major importance, inexplicably, the problem itself was considered
too little in the doctrine, but being instead very often debated in the audio-visual
media and political circles.
The central idea of such concerns in countries with modern democratic
regimes, is related to the possibility of obstructing some tendencies of the leaders
towards dictatorship and totalitarianism, the examples from the history of the last
century are eloquent in this regard, both in Europe and around the world.
Given the two forms of liability of the President, the research conducted is
focused on the scientific interpretation of the constitutional rules that relate solely
to the President's responsibility and to the need for constitutional amendments and
completions of some constitutional norms, which under an inadequate
formulations, it may lead to misinterpretations that are not in line with the will of
the constituent legislator.
Thus, in our opinion, the interpretation of the legal phrases “serious violation
of the provisions of the Constitution” and “high treason” is the key element, from
where to start when it comes to the political or legal responsibility of the
President.
Also the conducted research on the current constitutional rules, highlights the
fact that it has some flaws, that has to be regulated, because, as it has been argued
repeatedly in our doctrine also, the ambiguity of the legal rules can only lead to an
interpretation which is not in line with the will of the constituent legislator.
With more reason we sustain such an approach, since in our case, it is about
the fundamental law, a law that is designed to ensure normal operation of the state
law, with strict adherence to the principles of modern democracy.
The research is carried out as a point of departure for further studies, we have
in mind, which envisages ultimately the scientific argumentation concerning the
need to change and amend the Constitution regarding the duties and
responsibilities of the President.
This brief examination, referring to how to approach the responsibility of the
President in other fundamental laws of Member States of the European Union,
highlights a constant concern of these countries for addressing this major problem.
We appreciate that the political and/or legal responsibility of the head of state
must be oriented towards achieving two main objectives, namely: insuring the act
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of governance fallowing the basic principles of modern democracy and limiting
the powers of the presidential institution, in the sense of the inability to initiate
and support actions that lead to dictatorship and totalitarianism.
In this idea, the attempt to adopt the European Union Constitution (currently
abandoned), is in our view, a modern approach, which may constitute an
assurance that, at least within the European Union, the slide into dictatorship and
totalitarianism will not be possible.
References
Constantinescu, M. & Deleanu, I. & Iorgovan, A. & Muraru, I. & Vasilescu,
F. & Vida I. (1992). ConstituŃia României – comentată şi adnotată, Bucharest:
Regia Autonomă “Monitorul Oficial”
Constantinescu, M. & Iorgovan A. & Muraru I. &Tănăsescu E. S. (2004).
ConstituŃia României revizuită. Comentarii si explicaŃii, Bucharest, All Beck
Dănişor, D. C. (2009). ConstituŃia României comentată, Titlul I, Principii
generale, Bucharest, Universul Juridic
Ionescu, C. (2010). ConstituŃia României comentată şi adnotată cu dezbateri
parlementare şi jurisprudenŃa CurŃii ConstituŃionale, Bucharest, Universul Juridic
Ionescu, C. (2008). Drept constituŃional comparat, master, Bucharest, C. H.
Beck
Muraru, I. & Iancu, Gh. & Pucheanu, M-L. & Popescu, C.-L. (1993).
ConstituŃiile României, texte, note. Prezentare comparativă., Regia Autonomă
„Monitorul Oficial”, Bucharest
Romanian Constitution and 2 usual laws, Bucharest, Hamangiu, 2006
Rusu, I., DiscuŃii în legătură cu normele constituŃionale privind desemnarea
candidatului pentru funcŃia de prim-ministru de către Preşedintele României,
2008, in Dreptul no. 12, p. 108-115
Rusu, I., Raporturile Preşedintelui cu Parlamentul şi Guvernul. ObservaŃii
critice, 2010, Revista Transilvană de ŞtiinŃe Administrative, no. 1, p. 193-214
Spain Constitution, Bucharest: All Beck, 2003
The Constitution of Italian Republic, Bucharest: All Beck, 1998
The Constitutional Documents of the Great Britain and Northern Ireland,
Bucharest, 2003
