ABSTRACT
There are several expressions in the European languages which translate the concept of 'dissenting opinion' and, quite interestingly, they all put the institution in a different light. Examining these expressions represents a good starting point to achieve a deeper understanding of the nature of dissenting opinions. Judicial dissent may well emerge between different chambers of the same court or between different courts. Dissenting opinions may play a double role in legal research. The fact that constitutional courts have a monopoly on constitutional review does not only mean that they do not share this power with lower courts. There are important differences that distinguish constitutional courts from common law supreme courts, and they are relevant to a study on the practice of dissenting opinions. Constitutional judges are less attached to the traditional judicial mentality than ordinary judges, and they use different interpretative techniques and style of argumentation.
