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Because time is obviously limited. Let me say a few words on
the international dimension. The first written constitution was
written in North America in the late 18th century and swept over
to Europe from France to Germany. Step by step, the whole world
took the concept by learning. In Germany, from the very
beginning in the first constitution, there were foreign influences.
When we tried first time for democratic constitution in 1948 -
1949 which failed. American concept and French concept were
heavily discussed; it was even compared to which was the best
concept for Germany to adopt. So, learning by other is inherent.
I think of the discord of constitutionalism from the very outset.

The notion to the constitution that so deeply imbedded in
national specific culture that they cannot be transplanted and they
cannot be a migration of concept. What cannot be done on the
other hand is transplanting of complete concept and say okay I
adopt the German model of constitution and just take article 1 to
146 and take them. The only State I would think has token this
approach is Timor in current time where they took very much of
the constitution of Portugal and Mozambique obviously to my
knowledge but I am not too precise of the next stage of that
country. So, that cannot be done. I think one theory is called
curiosity of institutional law which is prevailing in Ikea furniture
shop where you can shop pieces of furniture and then assemble
them at home for yourself. I think that is quite nice comparison
where you can try to look to other country to their experience and
you try to find out what could work under your own condition,
what could work under specific national circumstances and there
you can probably have a good chance of result.

In 1949, when our German current constitution was made,
there was obviously of looking to the USA and other countries
when we discussed about introducing constitution into court
which is the biggest innovation that we have in our constitution.
There was intense discussion whether American supreme court
would not be the better one; unfortunately, they decided
otherwise, they choose Austrian model in 1920 which had not
proven that much of its quality until that time. So, I think
migration of idea is a good thing but should be done, obviously

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