...A Comparative-Constitutional Overview of ECHR and EU Law before National Courts. "The aim of this article is to answer the question, 'are national judges extending the structural EU law principles (primacy and direct effect) to the European Convention of Human Rights'? This article does not intend to examine the broader issue of the rapprochement between the legal systems of the EU and the European Convention on Human Rights (ECHR) but it concentrates on how national judges treat the norms of the ECHR compared with their treatment of EU law." (Quoted from paper)