La riforma costituzionale italiana nella dinamica dei modelli costituzionali della magistratura: l'apporto della comparazione

THE ITALIAN CONSTITUTIONAL REFORM IN THE DYNAMICS OF CONSTITUTIONAL MODELS OF THE JUDICIARY: THE CONTRIBUTION OF COMPARATIVE LAW. Based on the key elements of the constitutional reform on the judiciary currently under discussion in the Italian Parliament, this article offers a comparative analysis of the different national experiences in Europe with regard to constitutional models of the judiciary, proposing a classification that takes into account three essential elements: the nature of the judiciary, the guarantees of independence and status, and the forms of judicial government actually adopted. The aim is to provide useful elements for a critical assessment of the Italian proposal, taking into account the variability and dynamism of the identifiable models.