The final and most direct method of expression of the people is the constitutional referendum and it has become a near staple of modern constitution-making. Of twenty-three new constitutions promulgated in this century, thirteen have been approved in referenda.167 Carl Schmitt found the “people’s constitution-making will always expresses itself only in a fundamental yes or no and thereby [it] reaches the political decision that constitutes the content of the constitution.” At least “[t]heoretically” he went on, the plebiscite “corresponds thoroughly to the democratic principle and to the idea of the people’s constitution-making power