11 Aralık 2013 Çarşamba

Turkey’s Political-Constitutional Crisis: An Assessment of the Role of the Constitutional Court



Beginning in Spring 2007, the Constitutional Court of Turkey (CCT) has made several decisions that played allegedly a highly significant role in Turkey’s political-constitutional crisis. On May 1, 2007, the CCT decided that the parliamentary election process of the new president must be halted on the grounds that the initiation of the process has violated the constitutional procedures. Justice and Development Party (Adalet ve Kalkınma Partisi-JDP) reacted to this decision and called for early general elections while taking also the initiative to amend the constitution by a referendum to endorse a new procedure for the election of the president by popular vote, hence managed to overcome the initial phase of the crisis. Aware of the impediments they are likely to encounter in the near future, the JDP made simultaneously a bid for “a new civilian and democratic constitution”. Almost all political parties, with the single exception of Republican People’s Party (Cumhuriyet Halk Partisi-RPP), made equally explicit their will to constitutional renewal. In spite of an unquestionably non-democratic national threshold of ten percent, the elections produced a highly representative legislature, unprecedented since 1983, in which more than 87 percent of the votes were able to find a corresponding seat in parliament. In a moment so conducive as such to pursue in a democratic participatory fashion a new constitution, the JDP, in cooperation with the Nationalist Action Party (Milliyetçi Hareket Partisi-NAP) and betraying somehow its initial promises for a constitutional renewal, attempted to amend the constitution partially with the aim to lift the ban on headscarves in higher education.  In a case filed by RPP deputies arguing that the amendments mentioned violated the immutable principle of secularism, and therefore legally “null and void”, the CCT accepted the claims, thus turned down the amendments passed by 411 votes in a 550 member-parliament. Again in 2008, the CCT made a judgment that the governing JDP has become the center for anti-secularist activities, but fined the party instead of deciding for its closure. The case was filed by the Chief Public Prosecutor of the Republic, who in fact had warned the JDP beforehand not to amend the constitution to lift the ban on headscarves and if they so acted he would have no other chance but to file a closure case. As Turkey’s journey on the road to further democratization continues, the CCT decided very recently to close another political party on the grounds that the pro-Kurdish Democratic Society Party (Demokratik Toplum Partisi-DScP) became the center of activities targeting the “unity of the state together with its territory and the nation”.
All these critical decisions of the CCT have been influenced by and have had important implications in Turkey’s ongoing political-constitutional crisis. It is certainly true to argue that what Turkey has been going through since the rise of JDP to power in 2002 is a deep political crisis that cannot be reduced to a mere crisis situation in the legal system. What I mean by “political-constitutional crisis” in this context, thus, is a critical situation in which a political-legal regime finds itself caught in between what it used to be originally and a relatively uncertain future. In other words, the political-constitutional identity of Turkey defined in the late 1920’s and 1930’s and entrenched firmly in the Constitution’s immutables as a “homogeneous nation-state” is bound to change further as Turkey is experiencing “a transition from ‘equality’ understood as ‘sameness’ to ‘equality’ understood as ‘equality in diversity’”.[1] As this transition necessitates a shift from the original political decision to establish a nationalist constitution, it becomes also a crisis-ridden situation in which the CCT as one of the most powerful guardians of the status quo plays a crucial role.
In what follows, I would like to present an assessment of the role played by the CCT as put forward by its above-mentioned decisions. By way of introduction, I wish to begin by expanding on the political nature of Turkey’s constitutional crisis and situating the CCT in that context. In the second and third sections I focus on the positivistic and political-sociological interpretations of the recent decisions of the CCT. These decisions that reflect in a way the societal polarization between the supporters and the opponents of the JDP, have been extremely controversial in the Turkish public sphere. Amid these fervent political debates, however, it is still possible to discern at least two theoretically meaningful approaches to the role of the CCT in the constitutional and political process. I would like to call the first approach as “positivistic,” and the second as a “sociological and political” perspective, and try to outline the ways in which these approaches account for the CCT decisions and the overlapping or diversifying conclusions they reach. The positivistic approach gives us an opportunity to establish the contours of recent CCT rulings and the debates therein, while the political sociology perspective attempts to evaluate the role of the CCT within the Turkish political system. Finally, against the background of the legal positivist and political sociology perspectives, I wish to conclude the assessment of the role of the CCT in Turkey’s political-constitutional crisis by presenting an alternative approach inspired basically by the terms of debate in discourse theory of democracy.
I. Situating the CCT In Context
An adequate perspective that will enable us grasp fully the ongoing controversies over the recent decisions of the CCT has to bring together (a) the existing competences of the CCT as stipulated in the prevailing 1982 Constitution, and (b) the differences between the idea of constitutional review in liberal-democracies in general and the Turkish case in particular.
I.1. The CCT in the Turkish Constitutional System
The recent decisions of the CCT have triggered intense debates in the Turkish political public sphere because of their powerful impact on the political process in at least three key issues, two of which relate to whether and to what extent the CCT can review the constitutionality of parliamentary decisions on the one hand and the constitutional amendments on the other whereas the third pertains to the system of party closure.
According to the Article 148 of the Turkish Constitution, the CCT “shall examine the constitutionality, in respect of both form and substance, of … the Rules of Procedure of the Turkish Grand National Assembly [TGNA].” In view of this stipulation, the powers of the CCT in reviewing parliamentary decisions are restricted with the changes in “the Rules of Procedure,” i.e. the Bylaws of the TGNA. Exceptions to this restriction are the decisions that either lift the legislative immunity or have the effect of terminating parliamentary membership. Be that as it may, however, the CCT jurisprudence has established a strong tendency to review parliamentary decisions deemed as de facto changes in parliamentary bylaws. This tendency of the CCT to broaden the scope of its jurisdiction is of crucial importance for its direct impact on the democratic decision-making processes. This impact may enhance or distort or hinder the advancement of democratic politics. “Decision 367” discussed in detail below is a recent case in point.
As for the case of constitutional amendments, the CCT also tried to broaden the scope of its competence to include a substantive review of constitutional amendments. Article 148 again restricts the powers of the CCT in reviewing constitutional amendments. The provision (Art. 148/1) reads “[c]onstitutional amendments shall be examined and verified only with regard to their form.” Intended to restrict further the CCT’s powers, the same article (Art. 148/2) also defines what is meant by “form”: “the verification of constitutional amendments shall be restricted to consideration of whether the requisite majorities were obtained for the proposal and in the ballot, and whether the prohibition on debates under urgent procedure was complied with.”   Although the restrictions on the powers of the CCT in reviewing the constitutional amendments seem quite explicit, the CCT has continued, on certain occasions, to overcome these limitations. The court has done this by interpreting the concept of republican government not only as a legal form but also as a government inextricably intertwined with certain substantive values and principles like secularism, “Atatürkist nationalism”, as mentioned in the unchangeable articles of the constitution. Taking this interpretation of republican government as a starting point, the CCT relies on Article 4 which promulgates that “[t]he provision of Article 1 of the Constitution establishing the form of the state as a Republic, the provisions in Article 2 on the characteristics of the Republic, and the provision of Article 3 shall not be amended, nor shall their amendment be proposed.” Thus, the CCT assumes that it may strike down constitutional amendments conflicting with its vision of republican government on the grounds that amendments as such “shall not be proposed”.
In order to have a fuller image of the status of the court in Turkey’s political and constitutional system, the CCT’s powerful position in reviewing the parliamentary decisions and constitutional amendments must be taken together with the court’s powers in party closures. Article 68 of the 1982 Constitution establishes prohibitions on party statutes and programmes as well as party actions, and Article 69 provides for the standards, conditions, and procedures for party dissolutions. Based upon the conditionality of EU membership, these articles were amended in 2001 to render CCT decisions for party dissolutions more difficult. In view of the ECtHR rulings declaring almost all CCT decisions in party closure cases have violated the ECHR, and in view of a further constitutional amendment of 2004 in Article 90, it has been expected that the CCT would be more sensitive to the ECtHR rulings, hence more open minded for the development of pluralist politics in Turkey. Since the amendment mentioned reads “[i]n the case of a conflict between international agreements in the area of fundamental rights and freedoms duly put into effect and the domestic laws due to differences in provisions on the same matter, the provisions of international agreements shall prevail” , it was gathered that the CCT would resort to party closure decisions only as a last resort and in really exceptional cases of sheer violence. As discussed in detail below, however, the CCT acted to the contrary and tried to sustain its powerful position in Turkey’s political system.
I.2. The CCT vis-à-vis the Idea of Democratic Constitutionalism
The place of the CCT in Turkish constitutional system, i.e. in Turkish positive law, may be put in various perspectives. If one discussion, a rather popular one in recent public debates, is to evaluate the CCT from within different interpretations of Turkish positive law, the other is to situate the CCT in the general context of the idea of constitutional review and constitutional court in liberal-democratic politics. Although I provide an outline of the debate over the recent decisions of the CCT within the framework of legal positivism in the following section, I have to mention beforehand that legal positivism may reach different and even contradictory results about the role of the CCT in Turkish constitutional system, neglecting a highly significant dimension, that is the discussion of the relationship between the legality and legitimacy of the CCT rulings. Since the perspective of legal positivism identifies legality with legitimacy, this negligence may be understandable. However, the central problem about the CCT is inseparably connected not with the “legality” but rather with the “legitimacy” of the existing political order. Let me expand further on this point.
Students of legal and political theory are well acquainted with the fact that it was Hans Kelsen who developed the theory of constitutional review as an integral part of “democratic constitutionalism”. In the eloquent interpretation of Lars Vinx,

“Kelsen believes that the pure theory undermines the common assumption that the practice of constitutional adjudication is at least potentially in tension with democratic politics. If understood in the light of pure theory, democracy and the practice of judicial review of the constitutionality of all acts of the highest organs of government as well as of the legislature will be seen as mutually supporting institutions. Both democracy and constitutionalism are needed to provide a full institutional explication of the idea of legal objectivity and to realize the utopia of legality. Democracy, insofar as it is defined by its opposition to autocracy, is strengthened by constitutionalism and constitutionalism, as serving the purpose of the protection of minority interests, is meaningful only if we accept the legitimacy of constitutional review.[2]
Vinx argues further that this connection between democracy and constitutionalism (and constitutional review) gains meaning if we understand Kelsen’s pure theory of law not only as a “science” but also as a liberal-democratic political theory which puts forward a constitutional ideal called the “utopia of legality”. For Vinx,

“The utopia of legality is a constitutional system in which the legality, in the non-trivial sense of the term, of an act of state that enacts of executes a legal norm is ordinarily sufficient to make that norm (or act of execution) fully legitimate, to constitute a duty on the part of the subjects of the law to defer to and obey it. The reason for this is that the utopia of legality is a system in which people are subject, as far as this is possible, only to the objective rule of laws, and not to the rule of men.”[3]

Viewed in the light of the historical development of constitutional democracies in Europe and North America, the above-mentioned interpretation of the Kelsenian idea of the connection between democracy and constitutional review as a “utopia of legality” provides certainly the standards of evaluating actually existing constitutional systems. Thus, it becomes justified from within this perspective to ask if an existing constitutional system and the institution of constitutional review therein is in accord with the requisites of democratic constitutionalism?
As for the Turkish case, we have to take into account the meaning of constitutionalism in Turkey first and evaluate the constitutional review as practiced by the CCT later. There is certainly nothing novel in restating a well-established historical fact that Turkey emerged as a republic out of the ashes of a multi-ethnic and multi-religious Ottoman Empire. The fundamental concern of the founders of the Turkish Republic was to establish a homogeneous nation-state. Known best as Kemalism, this has been a very influential political ideology in which nationalism and secularism are the main pillars of the new political identity. Turkish constitutionalism, thus, has been determined by this nationalist blueprint and developed accordingly not on liberal-democratic lines as conceived by Kelsen, but has been “validated” by the “Turkish nation” whose identity has been defined by the political decision of a military and civilian bureaucratic (Kemalist/Atatürkist) elite. Accordingly, Turkish constitutionalism is obsessed primarily with the protection of the “territorial and national integrity” of the republican state against its “enemies”, external as well as internal. This overtly Schmittian framework of Turkish constitutionalism is now in a state of crisis since Turkey, with the “help” of global resurgence of democracy and multiculturalism, has come to discover that the Kemalist representation of society as a homogeneous entity is not true.[4] Both as a member of Council of Europe, a signatory not only to the ECHR but also to almost all international conventions on human rights and also as a candidate to full membership in the EU, Turkey has to adjust its constitution to the requisites both of supranationalism and multicultural democracy. As this adjustment requires a drastic change in the political decision which has determined hitherto the “Kemalist-nationalist constitutionalism” and rendered “valid” the existing order of things, it is justified to argue that Turkey is going through a political crisis. In view of the fact that the political origins of the CCT[5] explicates that the court was not envisaged as an instance of Kelsenian “utopia of legality”, but rather a guardian of an “absolute constitution” in the Schmittian sense[6], the recent decisions of the CCT discussed below could be situated as a ramification of a political crisis at the level of the Turkish constitutional system. In order to assess the position and the role of the CCT in this crisis-ridden situation, we may now go into the details of the debate over the recent decisions.
­II. Recent Decisions of the CCT in the Positivistic Perspectives
Before proceeding further, let me explain briefly what I mean by the term “positivistic”. Without going into the rather protracted debate between legal positivism and its critics, my use of the term positivistic in this context is an approach to the concept of law within the limits set out by what is known now as “exclusive positivism”[7]. According to this approach, there is a strict separation of law and morality, hence a corresponding separation between law and politics. Rejection of any critical attitude towards “the law as it is” as a sign of “natural law”, the positivistic approach claims to follow an allegedly scientific method in examining law and legal problems.
Despite its modifications into what is known today as “inclusive positivism,” this rather crude version of “exclusive legal positivism” summarized best by the motto “a law is a law, and an order is an order,” still prevails in Turkish jurisprudence and legal scholarship. Be as it may, however, exclusive legal positivism in Turkey in not monolithic in its approach to the CCT decisions. On the one hand there are those scholars who regard the CCT decisions as violations of Turkey’s constitution as it is, whereas there are others on the other hand who applaud the decisions as they see legally valid.
II.1. The “367 Decision”
As for the decision that stopped the parliamentary process of presidential elections known as the “367 decision”, for instance, there is the argument that the CCT breached the limits on its competences set by the Constitution and thus made a legally invalid judgment. This interpretation of the “367 decision” as legally invalid has two dimensions. The first in this regard is the interpretation of the Constitution as promulgating that CCT is authorized to review only “the constitutionality of laws, . . . decrees having the force of law, and the Internal Bylaws of the Turkish Grand National Assembly”. Thus, it is argued that CCT cannot examine the constitutionality of a parliamentary decision or procedure unless it is a change it its Internal Bylaw. Like in every rule, there are of course certain exceptions to this restriction like the parliamentary decision to lift the parliamentary immunity.
Even if this is the case, the CCT have made important decisions in the past in which it interpreted certain parliamentary decisions as changes de facto in parliamentary Bylaw, and hence treated them as subject to examination of constitutionality. Erdogan Teziç, a renowned professor of constitutional law has made an interpretation that if a parliamentary decision or a specific implementation of a parliamentary procedure endangers clearly and seriously the democratic rule of law based on human rights and liberties, then the CCT is justified to decide on its constitutionality, hence its annulment if required[8]. So, it has been suggested to admit that the criticism of the court as having breached the limits of its constitutional powers is not a criticism well established in Turkish positive law.
The second dimension, on the other hand, seems to have stronger grounds. Writing on this “367 decision”, Özbudun and Gençkaya claim that,

“the Constitution of 1982 (Art. 102) clearly described the procedures of the election of the president according to which a maximum number of four parliamentary rounds are foreseen for the election. The decisional quorum is two-thirds of the full membership of the Assembly on the first two rounds, and the absolute majority of the full membership on the third and fourth rounds, a minimum of 367 and 276 votes respectively. The Constitution contains no special quorum rule for the meeting of the Assembly, in which case the general rule in Article 96 should apply, that is, the quorum should be one-third of the full membership (184 votes).”[9]

Özbudun and Gençkaya further argue that the CCT judgment based on the interpretaion of the above mentioned articles as if the Constitution required a minimum quorum of 367 votes to begin the election process resulted not from a correct reading of the positive law but some “maneuverings of dubious legal validity started to ‘save the last citadel of the republic’ from the occupation of an alleged ‘Islamist’.”[10]
In contrast to the this argument implying that the CCT decision is not valid legally but a result of political maneuvering, another scholar of Turkish Constitution, Yüzbaşıoğlu has argued in a panel discussion organized in January 2007 by the Union of Turkish Bar Associations, that the first clause in Article 102 of the Constitution should be understood as an exception to the general rule (Art. 96) that stipulates the minimum quorum required for the convention of the Assembly.[11] According to the first clause (Art. 102), “the President shall be elected by at least two-thirds majority of the full membership of the Turkish Grand National Assembly and by secret ballot”. Yüzbaşıoğlu interprets this clause within its interconnectedness with subsequent clauses as an exception to the general rule set in Art. 96. It is this interpretation that the CCT adopted in making its decision some five months after this talk delivered.
What the forgoing examples suggest is that constitutional interpretations from within almost identical positivistic approaches to law have reached two opposite conclusions, each with its own claim to “legality”. This could be seen also in other decisions, most remarkably in the case on the unconstitutionality of the Constitutional amendments.
II.2. The Case of Constitutional Amendments
A second decision of the CCT subject to widespread criticism has been on the constitutional amendments of Articles 10 and 42. The amendment in Article 10 on the principle of equality before the law was the addition of the phrase “in all activities pertaining to the provision of public services” to the original wording “Organs of the state and administrative authorities are obliged to act according to the principle of equality before the law in all their transactions”. The new version of Article 10 as “Organs of the state and administrative authorities are obliged to act according to the principle of equality before the law in all their transactions and in all activities pertaining to the provision of public services” intended, as the justification of the law amending the constitution has written, to lift the ban on women’s headscarves in institutions of higher education. The parliament thought that endorsing a new clause, “No one can be deprived of the right to education without a reason written explicitly in the law” to Article 42 on the right to education would reinforce the amendment in Article 10.
In a case filed by the opposition in the parliament, the CCT first had to decide if and how it had the competence to review the constitutionality of constitutional amendments. This has been a hotly debated issue in Turkey since the inception of the Constitutional Court in 1961 Constitution. Originally, in the 1924 Constitution, the first Constitution of the Republic, Article 102 prohibited the amendment of the article defining the Turkish state as a republic. However, the 1924 Constitution had institutionalized a political system based on the notion of national sovereignty and the supremacy of the TGNA as its sole representative. In the 1961 Constitution, on the other hand, a system of separation of powers, most notably an independent judiciary was endorsed to check and balance the potential threats of a majoritarian democracy. In its original version there had been no limitations on the powers of the CCT, that is no restrictions existed when the review of the constitutional amendments were concerned. Shortly after the 1971 military intervention, however, the 1961 Constitution was amended in many respects, including a limitation on the CCT powers in reviewing the constitutional amendments. According to the new rule, the CCT could review the constitutionality of amendments only on formal grounds, without considering its substance.
In the 1961 Constitution, like its predecessor, there was only one immutable article and that was the first article stipulating “Turkish state is a republic.” After the above-mentioned restriction has been set, the CCT continued to consider the substance of constitutional amendments but justified its decisions on formal, not substantial grounds. In a decision in 1975, for instance, the CCT decided first that the immutability of Article 1 on the definition of the state as a republic encompasses also the qualities of the republic as mentioned in Article 2 that states that the republic is a secular, democratic social welfare state based on human rights and rule of law. On the basis of this initial decision, the court also decided that amendment that violate the qualifications of the republic do violate also the rule of immutability or even proposing any amendment to Article 1. What followed from this line of reasoning was the CCT’s annulment of the amendment foreseeing a change in the composition of a military court to enable at times of war the presence of non-jurist members violates the principle of the rule of law, thus the immutability of the definition of the state as a republic hence the proposition to amend the constitution couldn’t have been made. [12]
Having this past experience, the military junta of 1980, who in fact made the present 1982 Constitution, aimed to restrict further the competences of the CCT. Thus, after having stated that “Constitutional amendments shall be examined and verified only with regard to their form”, Article 148 stipulates that “the verification of constitutional amendments shall be restricted to consideration of whether the requisite majorities were obtained for the proposal and in the ballot, and whether the prohibition on debates under urgent procedure was complied with.” Although this was a restriction that curbed the powers of the CCT, the 1982 Constitution extended the scope of immutable articles both in numbers and in substance. Instead of one immutable article of the previous constitutions, the 1982 Constitution (Art. 4) endorsed the immutability of articles 1 (the Turkish state is a Republic) and 3 (and the qualifications of the republic as stated in Article 2 and those mentioned in the Preamble by Article 2. This extension of the scope of immutable articles helped paradoxically the CCT in restoring its previous powerful position in reviewing the constitutionality of amendments.
As for the case in 2008, the CCT has taken into account not only the wording but also the justification of the amendments. The court, then, established the fact that the amendments had the intention to lift the ban on women’s headscarves in higher education. On this factuality, the Court reiterated its earlier 1989 and 1991 decisions that allowing women students to wear headscarves in higher education institutions is against the principle of secularism for, (a) the headscarf is a symbol of religious fundamentalism, (b) in a society with an overwhelming Muslim majority, allowing to wear headscarves would become a source of social pressure over those who do not wear it and thus threaten social peace (mentioned also in Art. 2 of the Constitution), and (c) making law on religious concerns is not permissible under the principle of secularism. The CCT thus determined that the amendments violate the immutable principle of secularism, so the amendment cannot be proposed. Since the amendments under consideration cannot be proposed, the CCT decides that the amendments are “annulled”.[13]
Now, from within a positivistic perspective, the inclination of the CCT to extend the scope of its jurisdiction causes some serious problems so far as the decisions mentioned above, but most notably the most recent one, invites criticism for two reasons. The first reason stems from the fact that in the continental tradition of public law, it is a general principle that institutions of government, especially the executive and the judiciary are deemed incompetent unless they are so authorized by the constitution or the statute law. What follows from this principle is that, the rules that provide for governmental authority are exceptional thus cannot be interpreted in ways that extend the scope of authority, rendering the general principle meaningless. In the decisions mentioned above, it may be argued that the CCT did this in a manner that contradicts the principle about the sources of authority. The second reason for criticism points out that the court based its judgment not on the wording and the meaning of the amendments thereof but on their justifications that, in fact, had no binding force whatsoever. 
A counter but still positivistic argument, however, might be developed to defend the court. This time the argument would be based on a Kelsenian understanding of legal positivism conceiving law as a normative hierarchy in which every norm gets its validity from its superior. If this conception of law is adopted, then, it may be argued that the constitution is the supreme norm and it is the Constitutional Court who has the final authority in establishing the meaning of the constitution so as to judge the validity of laws in a legal system. In this specific case of the 2008 constitutional amendments, it should also be noted, the idea that constitutions gain their validity from their compliance with international law doesn’t help much because in the case of the headscarves, the European Court of Human Rights (ECtHR) accepted the CCT’s interpretation as “law” and made a judgment that the CCT’s decision which meant the endurance of the ban as not violating the European Convention on Human Rights (ECHR).[14] Here again, as in the previous case of the “367 decision”, we encounter another instance of reaching contradictory conclusions on the legal value of the CCT decisions from within the framework of legal positivism.
1I.3. The Case of Party Closures
Turkey is a “heaven” of party closures. Ever since the CCT is incepted, 26 parties have been have been closed and 19 of the cases fall under the term of the authoritarian minded 1982 Constitution. It is true certainly that the party closure cases are different in nature from the other cases we have already referred to above. Mention must be made here of the fact that both in the “367 decision” or in the constitutional amendments, the CCT performed a judicial function well known universally as the “constitutional review”, or more precisely, the judicial review of the constitutionality of the legislature. Party closure is different in that it is not a function of “judicial review” but bears more of a criminal law procedure. Performance of different judicial functions like “constitutional review” and a “criminal court” reveals that the CCT in the Turkish system has been so designed that it not only safeguards the Constitution, but also conceived as one of the guardian institutions of the Republic. Put differently, the CCT has a dual function, the function of protecting the rights and liberties of the individuals on the one hand and the function of protecting the Republic against the ills of the political parties, on the other. These two functions of the CCT can be contradictory at times for the Constitution has been the product of an authoritarian mindset as reflected in the problematic case of party closure.
According to the 1982 Constitution (Art. 68/para. 4),

“The bylaws and programmes, as well as the activities of political parties shall not be in conflict with the independence of the state, its indivisible integrity with its territory and nation, human rights, the principles of equality and rule of law, sovereignty of the nation, the principles of the democratic and secular republic; they shall not aim to protect or establish class or group dictatorship or dictatorship of any kind, nor shall they incite citizens to crime.”

In addition to these restrictions on political parties, there are numerous other prohibitions mentioned in Article 69 of the Constitution and in the Law on Political Parties. In the Turkish system of party closures, however, Article 68/4 has played a central role in closure decisions.
On several occasions, the ECtHR, deciding on the compatibility of the closure decisions with the ECHR, made judgments that the CCT decisions dissolving political parties has violated “the freedom of assembly and association”. The jurisprudence of the ECtHR, thus, played an important role in 2001 and 2004 amendments to the Turkish Constitution. Within the context of the most comprehensive constitutional reform package of 2001, the Constitution has been so modified that it became more liberal in its stipulations regarding the fundamental rights and freedoms and the party closure system has been changed also to render closure decisions more difficult. As Özbudun and Gençkaya describe,

“The constitutional provisions concerning political parties were amended again in 2001 to make the prohibition of parties more difficult. According to the amended sixth paragraph of Article 69, the dissolution of a political party on account of its activities contrary to the provisions of the fourth paragraph of Article 68 may be decided only when the Constitutional Court determines that it has become a focal point of such activities. A political party can be deemed to have become the focal point of such activities when they are undertaken intensively by the members of that party and when these actions are implicitly or explicitly approved by the general convention, or the chairperson, or the central decision-making or executive organs, or by the plenary session of its parliamentary group or its executive committee, or when these actions are directly carried out by the above-mentioned organs.”[15]

The 2001 amendments included further provisions with the purpose of rendering party closures more difficult like providing for an alternative sanction of cutting state funds in addition to the already existing permanent dissolution and bringing the requirement of a qualified majority (at least 7 out of 11 judges) for the Court’s decision on permanent dissolution. In addition to the 2001 amendments, a crucial amendment to the Article 90 of the Constitution has been made in 2004 to clarify a protracted concern over the normative status of the international agreements duly put into effect. In the earlier version, the article provided that international agreements duly put into effect have the force of law and, in a manner to distinguish the agreements from ordinary status law, proscribed claims to their unconstitutionality. The 2004 amendment added a new paragraph stipulating that in the case of a conflict between an international human rights agreement duly put into effect and a statute law, international agreements bear precedence over statutes. As Benhabib and Isiksel has already noted, “[t]his means that Turkish courts will now have to apply international law where it conflicts with domestic law, as national courts of EU member states have had to do since the establishment of the supremacy of EC law.” [16] Have they done so, or more precisely has the CCT done so?
In a recent decision on Rights and Freedoms Party (Hak ve Özgürlükler Partisi-RFP), another party representing predominantly the demands of the Kurds in Turkey, the court could not decide for its permanent closure for the number of judges voted for its dissolution remained short of the qualified majority now required. It seems, however, that the court in this case has been split into two in their interpretation of the supreme normative status of international human rights law. Six judges of the court who in fact decided to close the party, argued that Article 90 as amended in 2004 can be applied only if there is a conflict between a “domestic law” and an international human rights agreement like the ECHR. In the case at hand, the judges so argued that the conflict is not between domestic and international law but between the Constitution (Art. 68/para.4) and the international law. They argued that, in the concrete case at hand,

“the ‘domestic norm’ alleged to conflict with the article 11 of the European Convention on Human Rights is not a rule of a statute but a Constitutional provision. Thus, Article 90 has no relevance in this case. Moreover, according to the Article 138 of the Constitution, ‘the judges shall give judgment in accordance with the Constitution, law, and their personal conviction conforming with the law’ . . . and for this reason, it cannot be discussed for the Constitutional Court to leave aside these concrete Constitutional rules and establish a verdict by way of interpretation based on a direct application of the ECtHR jurisprudence.”[17]

The judges holding the view quoted above have relied not only on the articles of the Constitution, but also on the ECHR provisions that justify restrictions of freedom of association. The line of reasoning pursued in this respect puts the emphasis on the legitimate aim of protecting the territorial and national integrity of the state against which the RFP have been deemed to act.
In contrast to the majority view, five judges in the CCT have proposed that “political parties are under the protection of the Constitutional provisions pertaining to this particular subject matter and articles 10 and 11 of the European Convention on Human Rights regarding the ‘association’ and ‘freedom of thought and expression.”[18] They argued further that political parties shall not be dissolved on purely programmatic reasons without taking into account of seriousness of their actions as a threat to the democratic order of the state.
This split among the CCT judges is interesting extremely because this is the only case in which a considerable number of judges make reference to the importance of international human rights law. This portrays a striking divergence from the majority opinion which provides another example of the accustomed attitude in which reference to international law has been made either as mere lip-service or in justification for the restrictions on fundamental rights and liberties.
In the case of JDP and in a very recent decision on DScP, the court retained its already established jurisprudence in party closures. As for the JDP case, the court sustained its interpretation that lifting the ban on headscarves is a major act against secularism and relied primarily on this in deciding that the JDP have become a center for anti-secularist activities. Even if the CCT’s interpretation of secularism and the support it might have received from the ECtHR have been criticized[19], it is still a legally valid judgment. But, as in the previous cases discussed, in the party closure cases as well, it is possible to arrive at diametrically opposite conclusions within the framework of legal positivism on the legal meaning of the CCT jurisprudence. Take for instance the majority opinion in the RFP case. Here, the judges understand the positive Turkish law as a normative system in which the Constitution is deemed to be the supreme norm that validates all other norms in the system. Although this may contradict, yet again, the notion of law as formulated by Kelsen who rejected the dualism between domestic and international law, it nevertheless sustains its stronghold in Turkish jurisprudence and legal scholarship[20]. On the other hand, we are also enabled to criticize the CCT party closure decisions on the grounds still provided by legal positivism and argue that since Turkish positive law gives priority to international human rights agreements, the CCT must adapt its way of treating party closure cases to the requisites of international law.
III. Turkish Constitutional Court and the Turkish Political System
In view of the outline above of the recent CCT jurisprudence and the legal debates therein, it seems not implausible to assert that the contradictory conclusions regarding the “legality” of the CCT judgments reflect in an interesting manner the polarization between JDP supporters and opponents in society. At the risk of oversimplification of an otherwise more complex social reality, it may be argued that the supporters of the JDP see the CCT as a “politicized” institution acting as the bearer of tutelary power over democratic processes, while the opponents praise the court for defending the secularist Republic against its enemies.
This picture fits into a picture portrayed by an incisive sociolegal analysis of the CCT. Questioning “the link between judicial power and the expansion of rights,”[21] Ceren Belge has argued that “[b]y most standards of court power or activism in the literature, the CCT figures as a powerful court”[22]. Showing furthermore that the CCT’s activism was not affected negatively by the military intervention of 1971-1973, Belge makes a very important argument

“that the CCT’s failure to expand civil rights and liberties cannot be explained by its weakness vis-à-vis the other branches. Indeed, the CCT was both independent and powerful, I claim, but was activist only selectively. That is, the court used its clout to protect some groups and values while suppressing the demands of others.”[23]

In her analysis, the CCT protects what she calls “the Republican Alliance,” composed of civil servants, the judiciary and the universities, which means that the CCT has been “selectively activist” in certain rulings pertaining, for instance, to enhancing the autonomy of the judiciary while maintaining a ”conservative, nonactivist stance in civil liberties cases”[24].
Pointing out to the importance of societal allies for court’s power, Belge has asserted that

“[h]ad the CCT not had powerful allies, such as the military (at least initially), the RPP, and to a lesser extent the bureaucracy, university professors, and students, it would not have been able to overrule major policies of JP [Justice Party-Adalet Partisi] governments or of the emergency cabinet of the martial law era. Nor would the court get the opportunity to play a high-profile role in Turkish politics if Republican groups did not actively use the court in their struggles against popular majorities.”[25]

In view of the recent political-constitutional crisis, it seems possible still to reiterate a similar argument. The military, in its role in the presidential election process in 2007, the RPP, many university professors (including the then presidents), etc. are still within “the Republican Alliance” supporting the CCT activism in turning down not JP but JDP this time, and no doubt that “the Republican groups”, which included then President Sezer as well, actively used and still use the court, in their dealings with the “popular majorities”.
This penetrating “sociolegal” analysis of the CCT acquires further significance if situated in the broader context of Turkish history which suggest that what Belge calls “the Republic Alliance” has deeper roots in history than it might be recognized at first sight. In the pre-republican days of “national struggle”, for example, an analysis inspired by the October Revolution of 1917 of the social and political structure of the Ottoman-Turkish society proclaimed that the basic class cleavage in Turkish society was not between the bourgeoisie and the proletariat, but between the bureaucracy and the people. In his address to the First Grand national Assembly of 1920, the spokesperson of the “Special Committee” who provided a draft constitution came to be known as the 1921 Constitution argued that,

“the bureaucratic class in this country has believed as if they were placed in power by God’s will and thus they deemed themselves as having the right to command over the peasants and they have always uttered that without their power it would be impossible to govern the country. . . . [The Committee] has declared a war against this present form of bureaucratic government and has sworn to tear apart even in the provinces the bureaucratic hierarchy and the bureaucratic network. Accordingly, the Committee has adopted the principle of election of the officials in provinces by the locals, hence the principle of direct popular government.”[26]

This analysis had been put forward to justify a new constitution that would enable “the people” to govern almost directly within a highly decentralized system of government in which not only the parliament but also the governors of provinces would be elected directly by the people. Though constitutionalized, this decentralized democracy has never been put into practice and replaced instead by another constitutional system under which the RPP ruled over the society from 1923 until the popularly elected Democrat Party (Demokrat Parti-DP) took over government in May 1950. The DP rule between 1950 and 1960 marked the first phase in Turkish democracy which ended with a military putsch in May 1960.
To make short what might otherwise turn into a prolonged history lecture, the 1961 and 1982 constitutions endorsed some checks against popularly elected parliamentary majorities to “protect” the Republican order. Among these checks over majority rule has been the institutionalization of the role of the military in Turkish political decision-making process through the National Security Council, the Senate whose members are partly elected, partly appointed by the President, and partly comprising the members of the 1960 military government, ant the CCT. According to Mümtaz Soysal, a distinguished professor of constitutional law, the nature of this constitutional system is summarized best by what he calls “the fear from majority”. Beneath this fear, he explains, lies the assertion that “the people are ignorant, unable to make choices for its good; open to abuses”[27] In his analysis, the “military and civilian bureaucracy transfers its societal power to another, “tripartite power” made up of remnants of feudalism, local notables and the ‘new bourgeoisie’, or ties itself to it.” 1960 coup d’état was the result of bureaucracy’s discontent about the consequences of this transfer of power. This discontentment is reflected itself in the form of putting obstacles in front of a popularly elected majority power to “prevent it in drifting away from the ideals that has been established by the bureaucracy over a century.”[28]
What Belge calls “the Republican Alliance protected by the CCT” overlaps, in fact with what Soysal labels “military and civilian bureaucracy”, and both analyses somewhat support the relatively well established idea that the Turkish political and constitutional system is a mixture of democratic procedures with institutions of guardianship among which the CCT has a powerful place.
This diagnosis about the dualism of the Turkish political regime is reinforced further by the 1982 Constitution which strengthened the institutions of guardianship[29], most of which have been removed or mitigated as a result of the reforms between 1998-2006 under EU conditionality.[30] The CCT, however, seems to have not been affected from these reforms and sustains its activism in protecting the “Republican Alliance”, whose composition and societal bases might have been modified as the social fabric in Turkey has changed drastically over the decades from overwhelmingly agrarian and illiterate population of the 1920’s to a predominantly urbanized and literate population of the present.
This overall change in the social fabric and Turkey’s prospective membership in the EU coincided with the global resurgence of democratic ideals and values making things more difficult for the sustainability of the now outdated dualism of democracy and guardianship. As the legitimacy of its present institutional structure and competences has been under serious criticism, this difficulty is to be experienced by the CCT. In an important interview he gave to the Turkish daily Milliyet just after the CCT’s “non-closure ruling” in the JDP case, Andrew Arato has made some very critical remarks in this regard. According to Arato, it should be understood first that the CCT, not unlike other constitutional courts, supervises the formation of new constitutional rules, and the CCT itself is a major actor at least partially in the making of a constitution.[31] In his own words,

given the unchangeable articles, its Grand National Assembly is not a sovereign constituent assembly. It is important, that the consensual approach may neutralize political actors with standing who may appeal to the Constitutional Court to review the constitutionality of amendments: according to article 148   only the president or 1/5 of the deputies can do so, and the Court cannot initiate review on its own.  Given the unlikely case of the emergence of a consensual constitution, and the opposition of 1/5 of the deputies, it will be also important to take the views and interests of the Constitutional Court into account that would most likely concentrate on its own institutional interests. In short, a Court would fight above all the diminution of its own authority.”[32]

Arato’s second argument about the role of the CCT in Turkey’s constitutional processes is based not on sociological and political but

 “on principled grounds. In a society where there are such a sharp divisions about some culturally explosive symbolic issues, it may be a very good idea to leave a way of taking those issues out of the political process where ultimately, if one cannot agree, they lead to violent confrontations and the suppression of the weak, minority or majority.”[33]
IV. Insights of Discourse Theory and Concluding Remarks
This assessment of the constitution-making process in Turkey requires us to continue the discussion of role of the CCT within the framework not of normative theory. As regards Arato’s vision of Turkish society as sharply divided between “culturally explosive symbols”, this is true perhaps all contemporary societies across the globe in their experiences of cultural diversity. Perhaps not as explosive as in Turkey, many contemporary societies have been divided between cultural symbols and identities, making it all the more important to establish a new democratic rule of law, and Arato is justified certainly in his emphasis on the need of adding “some fundamental rights to what is unchangeable” in the Turkish Constitution, “even if such a feature is inevitably court strengthening.”[34]
The problem here is not with the power of the court, but with its selective activism in protecting the still undemocratic establishment of the republic and unyielding conservatism in enhancing rights and liberties. Acknowledging the importance of the role of the court, for instance, Benhabib makes the following assessment regarding the CCT’s annulment of the constitutional amendments of articles 10 and 42:

“We could say that all this is now ancient history, given that both amendments were rescinded and the status quo ante reestablished by the Turkish Constitutional Court. But it is important to that between February 2008, when the new legislation was passed, and June 2008, when it was overturned, Turkey missed the chance to create a new demos and a new political identity for a truly pluralistic society. It missed the chance to recognize the cleavage between observant and nonobservant Muslims as only one, and by no means the principal one, among the many differences and divisions in Turkish society.”[35]

Leaving aside the divisions of gender and class, other differences and divisions include those between Sunni and Alevi, between Hanafi and (mostly Kurdish) Shafii, ethnic differences, most notably the presence of a Kurdish population of at least 15 million, the decreasing number of non-Muslims, etc. On account of all these cleavages, we are compelled to reconsider problems faced by Turkey as problems of democratic legitimacy which could be overcome by advancing its reform process to create a new and inclusive political identity.
The fundamental issue here is not whether to strengthen the court other institutions to check and balance the excesses of majoritarianism, but to establish the procedures conducive for a democratic legitimation. What Habermas has diagnosed for contemporary complex societies holds true for Turkey as well:

“What grounds the legitimacy of rules that can be changed at any time by the political lawgiver? This question question becomes especially acute in pluralistic societies in which comprehensive worldviews and collectively binding ethics have disintegrated, societies in which the surviving posttraditional morality of conscience no longer supplies a substitute for the natural law that was once grounded in religion and metaphysics. The democratic procedure for the production of law evidently forms the only postmetaphysical source of legitimacy. But what provides this procedure with its legitimating force? Discourse theory answers this question with a simple, and at first glance unlikely answer: democratic procedure makes it possible for issues and contributions, information and reasons to float freely; it secures a discursive character for political will-formation . . .”[36]
So far as the “democratic procedure for the production of law” requires a constitutional system of rights and liberties, and so far as a system as such is need of courts to secure those rights, we encounter two types of problems, one pertaining to the institutional and procedural characteristics of the courts, the other what Ulrich Preuss calls the problem of indeterminacy.
As regards the institutional and procedural characteristics, we may put the emphasis on the idea that in a discourse theoretic understanding of democracy, courts must have procedural democracy as well. This means that the courts must be established in ways that connect them to the political public. In the case of constitutional courts, this means that the justices should be elected by the citizens or their representatives. This is certainly a requirement for the CCT for like all other high courts in Turkey, the CCT is formed also through a process of co-optation.
The second problem is more serious, because societies may find more democratic ways in establishing courts and their procedures, but the problem of indeterminacy stems from the structure of modern societies and undermines the “morality of law” and impeding a full procedural legitimation. According to Preuss,

“The law is supposed to safeguard both justice and certainty, i.e., the predictability of the parameters of individual and social action. . . . The indeterminacy problem refers to the fact that legal certainty has become problematic . . .  Aphorisms such as ‘On the high sea and before the courts we are in God’s hand,’ or ‘There is justice, but there are also courts,’ clearly demonstrate that the people’s trust in the predictability of court decisions has considerably decreased.”[37]

Taken together with Lon Fuller’s account of the morality of law in which one of the eight fundamental principles that make up the morality of law is formulated as “congruence between the rules as announced and their actual administration”[38], the problem of indeterminacy is a serious threat to legitimacy.
Upon these insights provided by discourse theory and non-positivist legal perspective, it seems to draw the following conclusions: (1) The CCT is a powerful institution in Turkey’s constitutional-political system. (2) The power of the CCT derives not from its democratic legitimacy, but from its allegiances with the power centers of the establishment, making it more of a guardian of the state than a constitutional court of rights and liberties. (3) The court’s decisions, as seen in the rather detailed examination provided in the first section of this article suffer from the “problem of indeterminacy”, making it less legitimate an institution than ever. (4) As the activism of the Court increases, as it has been the case during the recent political-constitutional crisis, its legitimacy erodes accordingly.
The eroding legitimacy of the CCT within the wider frame of still unresolved political-constitutional crisis calls for the urgency of setting up a totally new constitution. This requires both a consensus as inclusive socially and culturally as possible, a firm loyalty to the indispensability of fundamental rights and liberties and an understanding of the moral necessity of transition from a homogeneous idea of nation to a new political identity that acknowledges diversity in the political public sphere. Even if a constitutional renewal as such cannot take place, we may still be optimistic about the jurisgeneric potential in the still vibrant civil society of Turkey, taking caution, however, against the jurispathic dangers of the courts.[39]




Levent Köker is Professor of Public Law and Political Theory in Atılım University Faculty of Law, Ankara. Some of his articles in English were published in Political Theory and The Annals of the American Academy of Political and Social Science.


* This article is made possible to a great extent through my participation in a conference organized by Koç University on December 29, 2009 in Istanbul. I wish to thank my colleagues Fuat Keyman and Bertil Emrah Oder who enabled me to develop further my arguments here. I would like to thank also to my colleagues Çiğdem Sever and Abbas Kılıç in Atılım University, Ankara and an anonymous reader for their comments and suggestions on an earlier version.
[1] Seyla Benhabib and Türküler Isiksel, “Ancient Battles, New Prejudices, and the Future Perspectives: Turkey and the EU,” Constellations, 13, No 2 (2006), p. 230.
[2] Lars Vinx, Hans Kelsen’s Pure Theory of Law, Legality and Legitimacy (Oxford and New York, Oxford University Press, 2007), p. 145 (italics added.)
[3] Ibid., 25.
[4] Levent Köker, “National Identity and State Legitimacy: Contradictions of Turkey’s democratic Experience,” Elisabeth Özdalga and sune Persson, eds., Civil Society, Democracy, and the Muslim World (Istanbul, The Swedish Research Institute, 2002), pp.63-72.
[5] Cf. Ergun Özbudun, “Political Origins of the Turkish Constitutional Court and the Problem of Democratic Legitimacy,” European Public Law, 12 (2), 2006, pp. 213-225.
[6] Carl Schmitt, Constitutional Theory, trans. and ed. Jeffrey Seitzer, (Durham and London, Duke University Press, 2008), esp. pp. 64-65.
[7] Here I refer primarily to “the separability thesis” of legal positivism which “in its most general form . . . asserts that law and morality are conceptually distinct. . . . This [Klaus Füber’s] interpretation implies that any reference to moral considerations in defining the related notions of law, legal validity, and legal system is inconsistent with the Separability Thesis.” Kenneth Einer Himma, “Inclusive Legal Positivism,” in Jules Coleman and Scott Shapiro, eds., The Oxford Handbook of Jurisprudence and Philosophy of Law (Oxford and New York, Oxford University Press, 2002), p.135.
[8] Erdogan Tezic, Türk Parlamento Hukukunun Kaynakları ve İlgili Anayasa Mahkemesi Kararları (Istanbul: Istanbul Universitesi Yay, 1980).
[9] Ergun Özbudun and Ömer Faruk Genckaya, Democratization and the Politics of Constitution-Making in Turkey (Budapest and New York: Central European University Press, 2009), p. 97.
[10] Ibid. (italics added.)
[11] Necmi Yüzbasioglu, “Cumhurbaşkanının Nitelikleri ve Yetkileri,” in Cumhurbaşkanı Seçimi Öncesi Cumhurbaşkanlığı (Ankara, 12-13 OCAK 2007), (Ankara, Türkiye Barolar Birliği Yayınları, 2007), pp. 259-276.
[12] TCC decision dated April 15, 1975 (E. 1973/19, K. 1975/86).
http://www.anayasa.gov.tr/eskisite/KARARLAR/IPTALITIRAZ/K1975/k1975-087.htm (01.05.2010).
[13] TCC decision dated June 5, 2008 (E. 2008/16, K. 2008/116).
[14] ECtHR Grand Chamber Judgment in the “Case of Leyla Sahin v. Turkey”, Strasbourg (11/10/2005) http://cmiskp.echr.coe.int/tkp197/view.asp?item=1&portal=hbkm&action=html&highlight=Sahin%20|%20Turkey&sessionid=42981261&skin=hudoc-en
[15] Özbudun and Gençkaya, p. 58 (italics added).
[16] Benhabib and Isiksel, p. 224.
[17] TCC decision dated 01.29.2008 (E. 2002/1, K. 2008/1)
[18] Ibid.
[19] E.g. Carolyn Evans, "The 'Islamic Scarf' in the European Court of Human Rights," Melbourne Journal of International Law 4; (2006) 7(1), 52,
[20] It is worth emphasizing at this point that Kelsen’s understanding of the relationship between the international law and the constitution has changed from the first to the later versions of his seminal work Pure Theory of Law. In the words of Danilo Zolo, “Kelsen’s position on this crucial point nonetheless fluctuates. In Reine Rechtslehre. Einleitung in die rechtswissenschaftliche Problematik (1934) [. . .], the primacy of international law and the dissolution of the ‘dogma of sovereignty’ are presented as a technical outcome of the pure theory of law (English trans. Introduction to the Problems of Legal Theory (1992), at 124-125). In the second edition of Reine Rechtslehre (1960), at 343-345, Kelsen maintains that only the monist conception is laid down by theoretical requirement, whereas the choice between the primacy of international law and the primacy of domestic law can be based only on preferences of an ideological or political nature.” (Danilo Zolo, “Hans Kelsen: International Peace through International Law,” [italics added]
note 7. 01/05/2010).
[21] Ceren Belge, “Friends of the Court: The Republican alliance and Selective Activism of the Constitutional Court of Turkey,” Law and Society Review, Volume 40, No. 3 (2006), p. 685. Although this important analysis of the CCT is a survey of court decisions between 1962-1982, its conclusions are extended to cover also the turbulent days of Turkish democracy in the 1990’s, providing us with a highly reliable scholarly analysis for the present.
[22] Ibid., p. 665.
[23] Ibid., p. 654.
[24] Ibid., 674.
[25] Ibid., 686-687.
[26] Cited in Levent Köker, Modernleşme, Kemalizm ve Demokrasi, (Istanbul: İletişim, 2007), p. 141-142.
[27] Mümtaz Soysal, Anayasaya Giriş (Ankara, AÜSBF, 1968), p. 220.
[28] Ibid., 220-221.
[29] On the “tutelary character” of the 1982 Constitution see Özbudun and Gençkaya, p. 22-23. At this point, I think I have to explain why I choose the term “guardianship” instead of “tutelage,” a term with more common academic usage to describe contemporary Turkish politics. The term tutelage refers in a highly apologetic manner to the single party period of 1923-1945 and argues that Kemalist authoritarianism has been a historical necessity. Based on the theoretical assumptions of the modernization paradigm, the term puts an emphasis on the idea that the Kemalist single party period has had the idea of preparing the economic and cultural conditions for an eventual democratization of the political structure (For an eloquent exposition of this idea see Ergun Özbudun, “The Nature of the Kemalist political regime,” in Ergun Özbudun and Ali Kazancıgil, eds., Atatürk, the Founder of a Modern State, London: C. Hurst, 1981, p. 79-102). In contrast to this notion of political tutelage, guardianship emphasizes the endurance of an intrinsically authoritarian system of rule which conceives of the “Kemalist Republic” as the “ideal order” that needs to be protected not only against the external enemies, but also against the “wrongs” of the popular masses. The reaction of the military and civilian bureaucratic elites to the democratic reform process reflect not a “tutelary” mentality with the aim of eventual democratization, but rather a Platonic guardianship with the ultimate aim of protecting the existing order (i.e. the Turkish nation-state) against its “foreign and domestic enemies”. (Here I rely on Robert Dahl’s understanding of “guardianship” as an anti-democratic idea or a perennial alternative to democracy in his Democracy and Its Critics, New Haven, Conn.: Yale University Press, 1989.)
[30] For these reforms and “harmonization packages” see Özbudun and Gençkaya, pp.43-79.
[31] Andrew Arato, “The Decision of the Turkish Constitutional Court: the Way Ahead,” Frankfurt, August 9, 2008 (http://www.milliyet.com.tr/akp-ye-onemli uyarilar/siyaset/haberdetayarsiv/17.01.2010/982363/?ver=93, 01/05/2010). For an earlier account on the constitution-making process, see his “Forms of Constitution Making and Democracy,” Cardozo Law Review, Vol. 17 (1995), pp. 191-231.
[32] Arato, “The decision,”.
[33] Ibid.
[34] Ibid.
[35] Seyla Benhabib, “Turkey’s Constitutional Zigzags,” Dissent (Winter 2009). (http://www.dissentmagazine.org/article/?article=1321, 01/07/2010).
[36] Jürgen habermas, “Postscript,” in J. Habermas, Between Facts and Norms, Contributions to a Discourse Theory of Law and Democracy (Cambridge, Mass., the MIT Press, 1996), p. 448 (italics added).
[37] Ulrich Preuss, “Communicative Power and the Concept of Law,” in Andrew Arato and Michel rosenfeld, eds., Habermas on Law and Democracy: Critical Exchanges (Berkeley, Los Angeles, London: University of California Press, 1998), p. 327.
[38] Lon Fuller, The Morality of Law (new Haven and London: Yale University Press, 1964), p. 39.
[39] Seyla Benhabib, “Democratic Exclusions and democratic Iterations: Dilemmas of ‘Just Membership’ and Prospects of Cosmopolitan Federalism,” European Journal of Political Theory (2007), 6(4), p. 445-462. http://ept.sagepub.com/cgi/content/abstract/6/4/445 (01/12/2010).

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