Abstract
When, on the European continent, courts organized under a judicial bureaucracy were forced to issue reasoned judgments, the question arose as to how the plurality of judges was to arrive at a single judgment. The old procedure had allowed each judge to present his or her general opinion, and from these opinions a majority decision had been deduced, ignoring the strongest dissensions over the grounds by which the result of the decision had been reached. Adrien Duport (1759-1798), one of the members of the Triumvirate of 1789, had insisted on a vote in (two) distinct stages, an idea later taken up and elaborated in Geneva by Pierre-François Bellot (1776-1836). From there, this approach spread to Prussia, Hanover and other countries.
