This
paper undertakes a comprehensive comparative study of two of the world’s most
influential constitutional documents—the Constitution of the United States
(1787) and the Constitution of the People’s Republic of China (1982, amended
through 2018). Although both claim to embody the will of “the people,” they
represent fundamentally different traditions of constitutionalism shaped by
divergent historical, ideological, and political trajectories. The U.S.
Constitution reflects liberal-democratic principles rooted in Enlightenment
thought, emphasizing limited government, separation of powers, individual
rights, judicial independence, and federalism. In contrast, the PRC
Constitution institutionalizes socialist governance under the leadership of the
Communist Party of China (CPC), prioritizing collective welfare, state-directed
development, and democratic centralism.Historically, the U.S. Constitution
emerged from struggles against monarchical authority and sought to restrain
governmental power through checks and balances. The PRC Constitution grew out
of revolutionary struggles, national reconstruction, and ideological
consolidation under Marxism–Leninism and its subsequent Chinese adaptations.
Structurally, the U.S. system divides authority among coequal branches, whereas
China’s system fuses authority under the CPC, with the National People’s
Congress as the supreme state organ in form but operating under party
leadership in practice.
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