The general repercussion and the question prioritaire de constitutionnalité

milestones in a comparative perspective of the Supreme Federal Court and the Conseil Constitutionnel

Abstract

The comparative analysis between “Repercussão Geral” in Brazil and “Question Prioritaire de Constitutionnalité” (QPC) in France reveals a converging movement between two significantly diverse legal systems. Both mechanisms have sought to strengthen constitutional review and the protection of fundamental rights, each in its own way and taking into account their respective particularities. In Brazil, Repercussão Geral has transformed into an essential appeal filter that redefines the role of the Supreme Federal Court, bringing it closer to a precedent-setting court, while in France, the introduction of the QPC has significantly altered the profile of the Constitutional Council, granting it new institutional relevance and an unprecedented prominence to French constitutional jurisdiction.