Means of initiating constitutional action by persons "(A comparative study of Palestine, Egypt, France).

The Supreme Constitutional Court is an independent judicial body, where Palestine and Egypt centralize judicial control over the constitutionality of laws and resolve conflicts between the main authorities arising from the exercise of their respective jurisdictions, in accordance with the law establishing the Palestinian Supreme Constitutional Court No. 3 of 2006 and the Egyptian Supreme Constitutional Court No. 48 of 1979. The countries that have adopted the constitutional lawsuit system differed on the means of initiating the constitutional lawsuit before the Supreme Constitutional Court, some of which allowed individuals to appeal directly to the competent court, and others prohibited individuals from appealing directly to the court and decided it to the public authorities. Among the countries that allowed individuals to appeal before the Supreme Constitutional Court is the Palestinian legislator in the body of Article (27/1) of the Supreme Constitutional Court Law, through the original direct lawsuit, This is prohibited by the Egyptian legislation, which did not give this right to individuals, but allowed individuals to challenge the unconstitutionality of a provision in a law, regulation or system through a subsidiary defense in the text of Article (29/b), which is the same way that the Palestinian legislator also authorized individuals, in addition to the original lawsuit according to the text of Article (27/3) of the Palestinian Supreme Constitutional Court Law.