Comparative Analysis of Constitutional Frameworks, Fundamental Rights, And National Constitutional Identity: A Focus on Selected Jurisdictions

This study offers a comparative analysis of constitutional frameworks, fundamental rights, and the evolving concept of national constitutional identity across selected jurisdictions. By examining the structures, values, and interpretative approaches of constitutions from both common law and civil law traditions, the research highlights how different countries articulate and safeguard fundamental rights within their unique legal and cultural contexts. The analysis explores the role of constitutional courts, separation of powers, and amendment procedures in shaping the national identity embedded in constitutional texts. Special attention is given to doctrines such as basic structure, proportionality, and judicial review, as well as the impact of supranational entities like the European Union on domestic constitutional autonomy. The findings underscore the dynamic interplay between universal human rights norms and nationally rooted constitutional principles, offering insights into how states reconcile global constitutionalism with local democratic legitimacy and historical narratives.