proceedings before the Federal Constitutional Court (BVerfG), the fourth amendment to the Federal Constitutional Court Act of 21 December 1970 - in Section 30 (2) BVerfGG - introduced the possibility of a special vote. Since then, the decisions of the BVerfG can be accompanied by a minority opinion with the signature of the differing judge votes. The aim of the reform was to achieve greater transparency in court decisions and to strengthen the position of the individual judge. Special votes are also possible at some state constitutional courts in Germany. For example, Section 12 (1) of the Lower Saxony Law on the State Court provides for the corresponding application of Section 30 (2) BVerfGG. The Hessian State Court Law provides for an independent regulation on the possibility of a special vote in section 16 (3). Special votes are also permitted in arbitration proceedings. The special vote is only permitted at constitutional courts. A minority opinion may not be published in all other courts. A judicial confidentiality obligation arises from § 43 DRiG, which protects the confidentiality of advice. The introduction of special votes in all courts was discussed in detail at the 47th German Lawyers' Day in 1968. Italy A minority opinion cannot be published in judgments of Italian courts. In Constitutional Court a minority vote can be just guessed in case of "showy, not negligible distinction between the reporteur and the editor". According to Sabino Cassese, the absence of the dissenting opinion penalizes the potential that the process of constitutional review of the laws would have arouse debates and awareness in the country. Netherlands Dissenting opinions are not permitted by the Dutch legal system, but the wording of a published decision may reflect the divergent opinions of the ljudges involved. European Court of Human Rights Even though Europe has a civil law tradition, the European Convention on Human Rights explicitly states that judges of the European Court of Human Rights may attach their dissenting opinion to the judgment at hand. Criticism Susan Kiefel, Chief Justice of Australia, has expressed concern at the frequency of judicial dissents and the attention given to them by law students and legal commentators. She believes that they should be reserved for only the most important cases, and has described judges who frequently dissent as "somewhat self-indulgent". She further observed that "humorous dissent may provide the author with fleeting popularity, but it may harm the