Is there indeed a ‘right to privacy’ in comparative constitutional law? The question has been asked in constitutional legal scholarship whether the bundle of interests protected by ‘privacy’ are manifestations of the same underlying notion, or whether they are, rather, a set of disparate and unrelated rights.1 Thus, it has been described as a polymorph, protean, and heteroclite right whose content is unpredictable2 and ‘not susceptible of exhaustive definition’.3 Privacy is not mentioned in the constitutions of countries such as the United States and Germany,...
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