Court has five members: the Chairperson from the appellate division of the Supreme Court, two other judges from the Supreme Court and two further members, who must be South African citizens. 277. Mention should also be made of those situations where the appointment is made by the head of government based on the recommendation of the superior judicial council, as in the Palestinian Authority, or cases in which it is up to a specialized body or commission to select and appoint the members, such as a public service commission or judicial commission, or the Council for Citizen Participation and Social Oversight (Consejo de Participación Ciudadana y Control Social) in Ecuador. 278. Another variant is appointment by different public bodies. In Panama, for example, the executive branch, the legislative branch and the Supreme Court of Justice each appoint one member of the Electoral Court. As an example of the composition of an ad hoc body, in Afghanistan up to 2010, the Special Representative of the United Nations Secretary-General appointed the three international members of the Electoral Complaints Commission, and the two Afghan members were appointed by the Supreme Court (Stera Mahkama) and the Afghan Independent Human Rights Commission respectively. However, this composition ultimately proved unacceptable to President Hamid Karzai. 279. In France, three of the nine Constitutional Council members are appointed by the President of the Republic, three by the President of the National Assembly and three by the President of the Senate (Sénat). In addition to the nine members provided for above, former presidents of the Republic are ex officio life members of the Constitutional Council. Similarly, two members of the Constitutional Council (Konstïtwcıq Kengesí) of Kazakhstan are appointed by the President of the Republic, two by the Chairperson of the Senate, and two by the Chairperson of the Majilis (the lower house of the Parliament). The Chairperson is also appointed by the President of the Republic, and every ex-President of the Republic has the right to be a member of the Constitutional Council. 280. The Constitutional Court (Konstitucionen súd) of Bulgaria consists of 12 judges, one-third of whom are elected by the National Assembly (Narodno Sabranie), one-third appointed by the President and one-third elected by a joint meeting of the judges of the Supreme Court of Cassation (Vurhoven kasatsionen súd) and the Supreme Administrative Court (Vúrhovnija administrativen súd). Similarly, three of the nine members of the Constitutional Court of Georgia (saqarTvelos sakonstitucio sasamarTlo) are elected by the Georgian Parliament (saqarTvelos parlamenti), three are appointed by the President and three are appointed by the Supreme Court (uzenaesi sasamarTlo). Half the members of the German Federal Constitutional Court are elected by the 102

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