

- international
- study
In contrast to the classic federal constitutions (US, Switzerland, Canada, Australia) which are the product of 'coming-together' federations (aggregation), current functional federations in Africa are more of a 'holding-together' kind (disaggregation). It has been argued that where the formation of a federation is by aggregation, the amendment procedures are strict in giving the subnational units a determinative voice. The question is then where federal formation by disaggregation takes place, as is the case in Africa, is there then lesser protection for federal elements of a constitution? Has a new doctrine arose in Africa on this question? What has been the practice? The four case studies are Ethiopia, Nigeria, South Africa and Kenya.