Revista Temas de Derecho Constitucional

288 Revista Temas de Derecho Constitucional ABSTRACT The article analyzes the doctrine of conventionality control in a broad sense, that is not only as applied by the Interamerican Court, but also by other supranational legal sys- tems. The aim of the article is to understand if the nature of the conventionality control is the same as that of constitutional justice; or instead, if it is necessary to create a new theoretical framework for this instrument of protection of human rights. The author supports the idea that conventionality control and constitutional justice are based on very different principles and ratio, and that it would be methodologically more appro- priate to consider the “transnational conventional justice” as an autonomous disci- pline. In order to support her thesis, the author first of all studies the incorporation of international law into national legal systems; then, she analyzes the theory and praxis of the conventionality control, first criticizing the comparability assumptions, and then describing in details the functioning of the three supranational systems that apply the conventionality control (UE, IDH and EDU). PALABRAS CLAVE control de convencionalidad; justicia constitucional; ciencia jurídica; sistemas de ga- rantías de derechos humanos; desaplicación difusa KEY-WORDS conventionality control; constitutional justice; legal science; protection of human rights; judicial review