一、导言一般而言,各国宪法通常将修宪权授予代议机关行使,或者直接付诸公民复决。虽然在有的国家,行政机关或者国家元首也可部分参与修宪程序,但是,至少就宪法规范而言,很少国家授予司法机关参与修宪程序的权力。不过,修宪程序并不能得到全面有效的遵行,这是各国宪政 I. INTRODUCTION Generally speaking, the constitutions of various countries usually grant the right to amend the constitution to the representative bodies or directly to citizens for referendum. Although in some countries, the executive or the head of state may also be partially involved in the process of constitutional amendment, at least as far as the constitutional norms are concerned, few countries grant the judiciary the power to participate in the constitutional amendment process. However, the process of constitutional amendment can not be fully and effectively adhered to. This is the constitutional rule of all countries