Page:Studies in constitutional law Fr-En-US (1891).pdf/12

Rh clusion drawn from them. By a more rigid and continuous comparison with France, I have in this essay tried to recapitulate and bring out the differences not only in form and in structure, but in essence and in kind, between the Constitutions of England and the United States on the one hand, and France on the other. These differences are connected with the fundamental notion of, which differs in the three countries.