E Pouv 163 0005 PDF

Political parties in France’s Fifth Republic
Pascal Jan
In Pouvoirs Volume 163, Issue 4, 2017, pages 5 to 16
Translated and edited by Cadenza Academic Translations
Translator: Emma Mandley, Editor: Faye East, Senior Editor: Mark Mellor
ISSN 0152-0768
ISBN 9782021372731
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Pascal Jan
P O L I T I C A L PA R T I E S I N F R A N C E ’ S
FIFTH REPUBLIC
E mmanuel Macron’s election as President of the French Republic

was an event that had a number of ramifications. It delivered a
head of state who as a candidate was unaffiliated with any political party
I
represented in Parliament: instead, he was identified with a political

movement, En Marche! [Onward!], whose aim in the first instance was
to conquer the presidency and secure the National Assembly. Jean-Luc
Mélenchon, the candidate for La France Insoumise [France Unbowed]

subscribes to the same dynamic: breaking out of the party framework,
his movement seeks to marshal citizens looking for radical change and,
like En Marche!, claims independence from the parties that have long
been a fixture on the political spectrum. The second-round elimination
of the two candidates chosen in open primaries, who represented the
two parties of government that have alternately held power for decades,
clearly raises questions about the place of these political groupings within
the French political system. The shake-up of the party system and the
heralded rearrangement of political life around the two neo-movements
remain to be confirmed. The parliamentary elections of June 2017 sealed
the success of the presidential party, now called La République En
Marche!, with somewhat less positive results for Jean-Luc Mélenchon’s
party. The central axis occupied by the presidential party is too new to
allow for definitive conclusions to be drawn regarding any real reorga-
nization of political life or decline of the traditional party structure. But
a step has surely been taken toward ideological renewal and consistency
of political tendencies within parties, and toward their alignment with
the country’s deeply-felt aspirations.
While the traditional political parties have lost both credibility and
their monopoly as managers of democracy, this doesn’t mean their
P A S C A L   J A N
existence is threatened. It is their way of operating, their methods and

their strategies that are called into question, not their usefulness or
their function in democracy. The simple fact is that political parties are
concomitant with democracy and a system of representation, as Hans
Kelsen authoritatively demonstrated. 1 Even General de Gaulle, a fierce
opponent of the party system, believed that. “Nothing is more natural
than the existence of political parties. They are the expression of our
opposition to each other,” 2 he said at a conference on April 24, 1947,
following the launch of his party, the Rassemblement du peuple français
[Rally of the French People]. In any event, Article 4 of the 1958 French
Constitution enshrines their existence and broadens their functions. The
law offers them guarantees, especially in relation to finance, that assure
their real autonomy and freedom. This legal and financial framework
II explains the count of 451 parties and political groups registered by the
National Commission on Campaign Accounts and Political Financing.
This is sixteen times more than in 1990. Almost half of them are actually
micro-parties set up to address the need of many elected representatives for
extra financing for their political spending: as a source of complementary
funding, micro-parties have greater flexibility and independence than the
main parties to which representatives belong. The statistical fact is that

the high number of parties is largely a political fiction. Only a few are
representative, participating fully and regularly in political life (eleven
parties are represented at the National Assembly under the Fifteenth
Legislature of the Fifth Republic, aside from parties representing French
overseas territories and the nationalist party of Corsica.)
Th e r e g i m e o f t h e pa r t i e s i s d e a d ,
l o n g l i v e p r e s i d e n t i a l i s t pa r t i e s !
The lure of the presidential election, coupled with the need for the
president to obtain a parliamentary majority, is deeply disruptive to
the traditional party system, to the extent that the famous “regime
of the parties,” denounced so often by General de Gaulle, has been
thrown to the winds. 3 While the parties associated with parliamentary
1. Hans Kelsen, The Essence and Value of Democracy, trans. Brian Graf (Plymouth, UK:
Rowman & Littlefield, 2013) [La Démocratie. Sa nature, sa valeur, trans. Charles Eisenmann.
(Paris: Economica, 1988).]
2. Unless otherwise stated, all translations of cited material are our own.
3. In a televised interview with Michel Droit between the two rounds of the 1965 presi-
dential election, General de Gaulle said: “I proposed the 1958 Constitution to the country
P O L I T I C A L P A R T I E S I N F R A N C E ’ S F I F T H R E P U B L I C
sovereignty have failed in their intention to bring back the tempting

old-world parliamentary recipe that put governments at their mercy,
the political parties that have fully incorporated presidentialization in
their institutions have contributed to the establishment of a new party
system: the reign of presidentialist parties, that is to say the parties or
political movements that put the presidential election at the heart of their
political strategy and engage in a policy of forging alliances to help them
win parliamentary elections. The presidential and parliamentary electoral
systems (each involving a two-round majority) completely shape the
party system. Their impact on the polarization of political life has been
demonstrated in countless high-quality studies, including Jean-Claude
Colliard’s observations, which remain essential reference material on the
subject. 4 Since 1974, acceptance of the presidential election’s supremacy,
firstly by parties of the right and center and then by non-communist III
parties on the left, has thus fueled a right/left polarization whose modern
pattern was set in the parliamentary elections of 1849. But Emmanuel
Macron’s election and the victory of his cohorts in the parliamentary
elections in June 2017, which must be seen in the context of a festering
debate over the functioning of institutions and political practices, are
markers for a new polarization between a euro-progressive, liberal block

and a socially conservative block in favor of sovereignty—a polarization
whose features will be defined during the fifteenth legislature.
A presidential strategy
The procedures for the 1958 presidential election, followed by those
decided as a result of the 1962 referendum, were intended to reinforce
presidential autonomy and, by relying on plebiscite, to prevent parties
from creating a barrier between candidates and the voting public. The
election of president by direct universal suffrage followed on from de
Gaulle’s interpretation of the referendum as a way of overriding political
divides. Yet since the 1965 presidential election, political groupings have
again bounced back into the electoral landscape. L’Union pour la nou-
velle République [The Union for the New Republic] supported General
de Gaulle between the two rounds, while the Fédération de la gauche
[…] with the intention of putting an end to the regime of the parties. It was in this spirit that
the Constitution was created.” And he added: “We created confessionals to try and repulse
the devil, but if the devil is in the confessional, that changes everything.”
4. Jean-Claude Colliard, “Le système de partis ou la Constitution politique de la
Ve République,” Revue du droit public et de la science politique en France et à l’étranger 5-6
(1998): 1611.
démocrate et socialiste [Federation of the Democratic and Socialist Left]

was established on the heels of François Mitterrand’s decision to stand
as a candidate. This experience taught Mitterrand the dangers of having
a support structure that was too weak, and in 1971 he went on to create
a party that would act as a fighting force to win presidential elections.
The trend would become more established from 1974 onwards and has
remained consistent ever since.
To an extent, the organization of open primaries by the government
parties accentuates the parties’ hold on the presidential election, which
has been reduced to a competition between representatives of political
parties—a long way from de Gaulle’s original intentions. The second
round no longer involves a broad gathering, going beyond political
divides, but an inevitable muster of one camp against another. However,
IV Macron’s victory in 2017 seems to challenge this assumption and, for
the first time since 1965, reinstate the original notion of the presidential
election. The victory, confirmed in the parliamentary elections, of a
candidacy Macron described as being “as much on the right as on the
left,” nevertheless very quickly risks becoming “more on the left or
more on the right,” reopening the right/left fracture in the electorate.
The future will reveal the outcome of this new chapter in the institutions

of the Fifth Republic.
In any case, the political groups that accept the centrality of the presi-
dential election—although some of them may do so reluctantly—maintain
their position in national and/or local games of politics. Those that fight
against it sink without trace relatively quickly. This is precisely why the
parties that are most hostile to the Fifth Republic, including the parties of
the extreme left, have no choice but to support the presidential election
if they want to stay afloat, thus legitimizing it and bestowing it with the
importance its creators envisaged. As Pierre Avril wrote, “a party can
only maintain an autonomous existence and develop its own strategy if
it is situated within a presidential context.” 5 Thus, the political parties
that make the presidential election the cornerstone of their strategy for
achieving power hold their own on the political playing field. They can
aim for supreme power, or failing that perform well in parliamentary
and local elections when these are partially or wholly organized on the
basis of proportional representation. This means that ultimately the
presidential election, far from acting as a defense against the parties’ grip
on political life, stimulates the machinery of party politics.
5. Pierre Avril, Essais sur les partis politiques (Paris: LGDJ, 1990), 212
The search for the right candidate is so obsessive that the parties have
no hesitation in depriving their executives or their party activists of the
nomination and conferring it instead on supporters whose political
pedigree cannot be guaranteed. For the least representative parties, or
newly formed political movements, the presidential election represents an
invaluable test bed for advancing their candidate’s access to the position
of challenger, a fortuitous platform from which to try and disrupt the
party-political game, and an ideal competition in which to promote their
ideas. From this point of view, the presidential election is very valuable to
small and newly formed political groups, and even to completely marginal
parties so long as their candidates surmount the obstacle of selection
by local elected representatives. With their conspicuity assured, these
political groups can hope to draw in a significant number of voters in the
parliamentary elections, which since 2002 have followed on the heels of V
the presidential election. They will thus profit from the financial benefit
granted to candidates put up by parties that obtain at least one percent
of votes in at least fifty constituencies (in 2017 each vote commands
€1.42 per annum for the duration of the legislature). This fact explains
the proliferation of candidates at parliamentary elections (in 2017 the
average for each constituency was fourteen). If they fail to be compet-

itive in the parliamentary elections, these political parties can become a
recruiting ground for representatives in the local elections when these
are organized according to a more or less proportional format. When
European elections are added to the mix, these electoral competitions
contribute to the continued existence of such parties.
Organization centered on presidentialism

Having a strategic presence in the presidential election, to prepare their
audience for other elections, is not the only thing that characterizes
the presidentialist parties. They also organize themselves so that their
leader—intended, selected, or elected—benefits from the party’s support
when the time comes. They see themselves as offering a conduit for
presidential action if their candidate is elected. The presidentialization
of parties, encouraged by a two-party or three-party system, is a reality
that has long been established and described. It implies that a presi-
dential election candidate must take direct control of a political group
and, if he or she is elected and in the context of a new candidacy, must
directly or indirectly retain responsibility for its leadership. Losing
control of a party, and/or failing to overcome its internal differences,
means electoral failure for a candidate identified with it or benefiting
from its support. It can even mean the party’s decline in the event of
repeated defeats and if no alliance with a political party is formed in
preparation for parliamentary elections. L’Union pour la démocratie
française [The Union for French Democracy] foundered because of its
inability to unite behind its candidates; the Socialist Party is in a state of
near collapse in 2017 because of its ideological and strategic divisions;
while the Democratic Movement has had a new beginning as a result
of its alliance with the presidential party, La République En Marche!
Nationally, the Communist Party is stagnating because of its repeated
failure to present a candidate from within its ranks and this is having an
impact on its local operations, which are vastly diminished, and on the
loyalty of its voters, which is inexorably crumbling away. While on the
one hand the open primaries distance the party machinery from the choice
VI of candidates, on the other they reinforce the presidentialist strategy.
The emergence of new political movements such as En Marche! and La
France Insoumise demonstrates the persistent lure of the presidential
election, since these two groups were created first and foremost for the
purpose of achieving power at a national level. They were consequently
set up with a remarkable vertical decision-making structure: there is no
competition for the candidate at the presidential elections and the choice

of candidates for the parliamentary elections is centralized.
The presidentialist parties, which moreover cultivate the personal-
ization of power, only rise to the top of the political pyramid if they can
organize themselves so as to obtain a double majority, both presidential
and parliamentary. This is what determines their hold on political life
and their political audience. And that is why presidents, like all leaders of
political parties, cannot ignore the election campaigns of deputies or the
political line adopted by the party they belong to, or that supports them.
T h e d e b i l i t y o f p o l i t i c a l pa r t i e s
For many years, traditional political parties have been out of favor with
the people, who reject them despite becoming increasingly engaged in
society’s many different causes. Party activism is flagging, membership
is plummeting. The parties are viewed by the younger generation not as
movements but as brands to which they may subscribe for a while but
which they abandon without a backward glance. Any loyalty to a party
is superficial. But the crisis is not simply one of finance and activism.
It is connected to an excessive recourse to the law to resolve internal
political conflicts and perhaps still more to the organization of open
primaries, which are destructive to the very unity of the groups that
have fallen for the apparent charms of so-called participative democracy.
The snare of primaries

The French system of primaries was inspired by the US model that
developed at the end of the nineteenth century and became established
in the twentieth, but is organized somewhat differently. Primaries (at
first closed and later open) initiated by the governmental parties of
both left and right have substantially destabilized political groupings
disinclined to marginalize their leadership apparatus. Open presidential
primaries were adopted in 2010 by a Socialist Party badly in need of
leadership and by the environmental party Europe Écologie-Les Verts
[The Greens], which was plagued by internal divisions. They represent
an evolution toward the left that began in the middle of the 1990s (with VII
votes for active party members) and continued in the middle of the
2000s (semi-open primaries with votes for “€20 members”). In 2016,
primaries were foisted on a right wing governmental party culturally
unsympathetic to this approach to candidate selection, although since
2006 it had allowed its members to choose its leaders in order to prevent
a proliferation of candidates in the first round of the presidential election.

For it is indeed the presidential electoral competition that determines
these shakeouts and prompts these pre-election selections. The party
machinery is marginalized. Primaries, especially when they’re open,
thus represent a snare for the political parties that succumb to them.
They lose their identity and their very existence is threatened. The
primaries are seen as a remedy to the parties’ representative crisis and
to dwindling party memberships, and as a solution that gives new legit-
imacy to political parties lacking uncontested leaders. But—running
counter to the spirit of the Fifth Republic and the presidential election
as conceived in 1962—they also represent a much greater threat to those
parties that, until the early 2010s, were able to win the presidential and
other political elections.  
There are shared similarities in the organization of open primaries
(such as payment of a modest fee for participation, the involvement of
higher authorities to control and assure the polling process’s legitimacy,
competition open to several political groups, and voting open to all
bona fide voters on the electoral lists), but more importantly primaries
overcome the inability to manage competing personal ambitions internally.
In the tri-partisan context that has been dominant since the middle of
the 2000s, the primary entails an initial “triage” of the candidates. This
reduces the fragmentation of votes in the first round of the presidential

election: only the two best candidates in terms of votes cast will be in
competition for the final prize. Weeding out candidates within their
own camp is the objective of this preliminary round, organized for the
moment by the main parties of government.
While this system is all the rage and has had much media coverage,
it incorporates some serious drawbacks. The 2017 presidential election
is a reminder that the system in no way guarantees the winners of the
primaries an advantage in terms either of uniting their party or of cre-
ating the best conditions to present themselves to the voting public as
a whole. The potential pitfalls of such a strategy were exposed in the
second round of the 2017 presidential election, with the elimination of
the two candidates who emerged from primaries (after the Green Party
VIII candidate, who also came through an open primary, withdrew in order
to support the socialist candidate). Primaries do nothing to prevent
either dissidence or disloyalty, nor can they impede non-conformist
and independent candidates, such as Macron and Mélenchon in 2017.
Above all, the weakness of political parties who buy into the open
primary formula for the preselection of candidates is underlined when
the winner represents a minority element of the party, unforeseen by

the party machinery (François Fillon and Benoît Hamon in 2016-2017,
François Hollande in 2011). In the Socialist Party, since 1995 external
and/or minority candidates within the party apparatus were already
being systematically selected through closed primaries (Ségolène Royal
in 2007 against Dominique Strauss-Kahn). Open primaries attest to the
party machinery’s loss of control over the selection of candidates. This
“law of primaries” is problematic in terms of the management of the
future presidential party if two or three political tendencies co-exist
within it, sometimes taking very different positions. The unity of the
presidential party is threatened by the slightest frustration of the losing
faction. François Hollande’s five-year term is a clear example of this.
The “rebels” never gave up their backing for the doctrine supported by
Martine Aubry, the loser in the 2011 Socialist primary, to the point of
preventing François Hollande from aspiring to a second and final term.
A split in the party can even be a factor before the start of an official
campaign (Fillon and Hamon in 2017). It is true that open primaries have
not yet been introduced in all parties. But their deadly effect is evinced
by the fact that they bear upon parties that have governed since the early
1980s and whose candidates were eliminated in the second round of the
2017 presidential election.
Lastly, the proliferation of primaries threatens the very functioning

of the constitutional system. Open primaries are popular. They suggest
a more “participative” democracy. Indeed, the increased participation
of citizens shows their approval for the introduction of a preliminary
round. However, there are other serious objections to primaries to add
to those already described. It is certainly true that they prevent the
party machineries, with their chieftains and barons, from holding a
monopoly over the choice of candidate. It is equally true that primaries
widen access to the political world. And it is also true that democratic
nomination usually, but not inevitably (Fillon in 2017), guards against
internal divisions. Nevertheless, this pre-election election is another
small step toward the parties’ demotion, downgrading them effectively
to presidential backing teams and—worryingly—relegating their policy
development function to second place. The undeniable enthusiasm IX
for primaries presumes that they guarantee to reduce the number of
candidacies in each camp. Yet the 2017 presidential election has defin-
itively (and happily) overturned this theory, since the final ballot was
contested by two candidates who did not emerge from primaries but
presented themselves as “outsiders.” Finally, while the primaries galvanize
citizens around the presidential stakes and encourage participation in

political life, they also inflate the personalization and dramatization
of the election. They reduce political life to a horse race: a chase after
votes, to the pace of opinion polls. In fact, primaries destroy the parties
prioritizing members—the traditional structures—and turn them into
parties prioritizing voters, not to say supporters. Party members lose
the only real power they had, acquired belatedly on both the left (by
the Socialist Party in 1995) and the right (by the Union for a Popular
Movement in 2006): the ability to nominate their candidate for the
presidential election. The En Marche! movement is a good example of
the way priority is now given to electoral affairs rather than activism.
We are looking at a complete shake-up of party politics.
The increased emphasis on the law in the management

of internal relations
While political parties are now governed by the law in terms of the
financing of political activity and electoral campaigns, the law is also
increasingly put to use when it comes to the functioning of political parties.
Judicial rulings over internal disagreements show the increasing fragility
of political parties: they have become incapable of sorting out their own
affairs. Political battles lost within the party are pursued in the courts.
Disputes over political parties’ statutory regulations have only recently

materialized. They demonstrate the consequence of enacting an increas-
ingly detailed disciplinary law specific to political parties, but equally
the effect of the growing number of procedures for selecting election
candidates (through open primaries), generating legal challenges. Thus,
at the end of 2016, Gérard Filoche, challenging his exclusion from the
election, unsuccessfully sued the Socialist Party secretary, Jean-Christophe
Cambadélis, and some of the organizers of the left-wing primary. As
Jean-Jacques Urvoas points out, recourse to the law to sort out the
party’s internal matters “is evidence of the collapse of loyalty, once the
cement holding the party together […] In my view, the intervention of
the courts means that the ability to debate issues is being replaced by
the victory of one faction over another in the organization of politics. I
X believe that this is a sign of weakening, characterized by an absence of
dialogue within the parties. Their members can no longer talk to each
other and so refer to a third party to tell them who is right and who is
wrong, rather than finding a way for them to go on living with each
other.” 6   
The law has become an instrument for regulating the parties’ opera-
tions. Members no longer hesitate to appeal to the courts to challenge

the application of statutory regulations, or even their party’s political
line. Internal debate seems to have died a death, compromise seems to
have become impossible. Recourse to the law as a vehicle for internal
challenge in order to pursue an external objective has become a com-
monplace course of action for many party activists. There is no doubt
that such appeal to a third party discredits a political party in the eyes
of the public, inevitably laying bare the dysfunction within it. The law
is used as a lever of political action in many situations, from drawing
up the list of candidates in local and national elections to disciplinary
sanctions. In the ordinary court, the judge will always emphasize that
his or her jurisdiction is based on the legal status of the party, that is
to say a private association, and refrain from any assessment of the
appropriateness of its political decisions, focusing solely on the extrinsic
legality of the contested events. So as not to go further into the internal
affairs of the party, both the ordinary court and the administrative court
also hold back from providing a positive standard with which to define
6. Jean-Jacques Urvoas. 2015. Speech at the conference “Le droit interne des partis politiques”
[The Law within Political Parties] hosted by the Association française de droit constitutionnel
[French Association for Constitutional Law], Paris, September 30.
political parties. The Council of State is content to refer to the need

for approval from the National Commission on Campaign Accounts
and Political Financing; 7 the Supreme Court applies the ordinary law
relating to associations and defines a party from a negative perspective,
taking the view that a political group does not take part in the exercise
of a public service mission. 8 Nonetheless, the increasing recourse to
the law in relation to the internal operations of political parties points
up not only the stormy relationships they harbor but also the evident
willingness of party activists, minor politicians, and even salaried staff,
to defend their opinions and their rights by means of challenges to the
application of statutory or ordinary disciplinary regulations.
The involvement of the courts in the functioning of political parties
should certainly not be exaggerated. 9 For example, the aims of a party’s
activity are not considered by the courts except when they come into XI
conflict with article L. 212-2 of the internal security code, which prohibits
illegal activities such as incitement to violence, hatred or discrimination
“toward a person or group of people on grounds of their origin, or
their affiliation or non-affiliation with any ethnic group, nation, race or
religion.” Nor do the courts hold political parties to the rules applicable
to business (trademarks and unfair competition). In this context, the

Paris Appeal Court, in a judgement on September 24, 2015, rejected the
demands of the Fédération nationale des élus socialistes et républicains
[National Federation of Socialist and Republican Deputies], which chal-
lenged the appropriation of the name “Les Républicains” by a political
party. Equally, article 4 of the French Constitution provides for political
parties to enjoy an almost complete freedom of action, a freedom whose
safety is assured by the European Court of Human Rights. Finally,
election judges refuse to be manipulated by those who seek to make
them adjudicate on nominations, except in the case of proven fraudulent
procedures. In any event, administrative judges for interim proceedings
hold that it is not within their jurisdiction to make such decisions, which
cannot be separated from disputes over the electoral process. 10 That being
the case, it is important not to under-estimate the tendency, in certain
7. Conseil d’État, October 30, 1996, no. 177927 “Élections municipales de Fos-sur-Mer.”
8. Cour de Cassation, Première chambre civile, January 25, 2017 “Front National v. Jean-
Marie le Pen.”
9. Jean-Pierre Camby, “Les partis peuvent-ils avoir un juge?” in Le droit interne des partis
politiques, ed. Julie Benetti, Anne Levade and Dominique Rousseau. (Paris: Mare & Martin,
2017), 129.
10. Conseil d’État, June 2, 2017, no. 411015.
quarters, to try and make judicial oversight of statutory regulations or

internal decisions (such as refused membership, exclusion, appointments)
a commonplace. This tendency betrays a serious weakness in the parties,
which are incapable of internally managing conflicts that are principally
political but are given a legal complexion for the sake of expediency.
Calling upon public opinion and especially the electors speaks more of
political strategy than a real desire to engage the courts in substance.
The law’s hold over the political parties’ operations and their recourse
to the courts explain why the main political parties that have succumbed
to the deadly charms of open primaries have followed the model of
independent administrative concerns and put in place higher authorities
charged with resolving, outside the courtroom, conflicts and disputes that
arise during the ballot. The establishment of such authorities indicates
XII that the parties are no longer able to offer, to their members and to those
outside the party, the necessary guarantees of independence and objectivity
in the application of some of the regulations governing their operation.
Concealed behind a respect for standards, this acknowledgement mostly
provides evidence of an alarming debility in the parties’ own leadership,
which is unqualified to regulate certain procedures, namely those con-
cerning the nomination of candidates for the presidential election and

even the parliamentary elections.
A B S T R A C T
Lacking specific legal status, French political parties are experiencing a major
crisis, as dramatically revealed by the presidential and parliamentary elections
in May and June 2017, as well as by the growing recourse to the law in their
internal functioning. Yet the new political movements, like the endangered
traditional parties, are just as president-centered in their strategy as in their
organization.
Pascal Jan is a specialist in public law and senior lecturer at the Bordeaux
Institute of Political Studies. An authority on France’s Fifth Republic,
he recently published La République gouvernée (1958-2017), the third
and final volume of Constitutions de la France (Paris: LGDJ 2016-2017).
Translated by Cadenza Academic Translations

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Political parties in France’s Fifth Republic

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E mmanuel Macron’s election as President of the French Republic

represented in Parliament: instead, he was identified with a political

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existence is threatened. It is their way of operating, their methods and

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sovereignty have failed in their intention to bring back the tempting

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démocrate et socialiste [Federation of the Democratic and Socialist Left]

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Organization centered on presidentialism

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The snare of primaries

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reduces the fragmentation of votes in the first round of the presidential

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Lastly, the proliferation of primaries threatens the very functioning

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The increased emphasis on the law in the management

Disputes over political parties’ statutory regulations have only recently

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political parties. The Council of State is content to refer to the need

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quarters, to try and make judicial oversight of statutory regulations or

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Translated by Cadenza Academic Translations

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