[TAR Lombardia – Brescia sent. n. 1 del 5 gennaio 2012] Nelle giunte comunali deve essere garantita la rappresentanza di genere anche se non espressamente prevista dallo Statuto

Con la prima sentenza del 2012 il TAR Lombardia – Brescia ha avuto l’occasione di esprimersi sulla questione del rispetto delle quote rosa negli organi politici e amministrativi degli enti locali.

La pronuncia accoglie il ricorso presentato da alcune cittadine del Comune di Ghedi, titolari del diritto di elettorato attivo e passivo, le quali impugnavano tre decreti del sindaco con i quali venivano colmati due posti vacanti della Giunta comunale, procedendo alla nomina di due assessori di genere maschile e rendendo nulla nella stessa Giunta la presenza femminile. A giustificazione dei decreti di nomina il sindaco specificava che era stata inutilmente sondata la disponibilità di cinque donne, affini politicamente e preparate culturalmente, ad assumere dette cariche.

Dopo avere ribadito la natura collettiva dell’interesse a ricorre in questo caso, determinato dalla necessaria e progressiva espansione delle pari opportunità negli organi politici, e l’impugnabilità delle nomine degli assessori avanti al giudice amministrativo (da ultimo confermata da una pronuncia del Cons. St. sez. V n. 4502 del 2011), il TAR individua i fondamenti normativi posti a tutela delle pari opportunità nell’art. 23 della Carta di Nizza e nell’art. 51 Cost.

In particolare, la giurisprudenza della Corte costituzionale ha individuato nell’art. 51 Cost. un vincolo, applicabile alla formazione degli organi che non siano direttamente elettivi, comprese le Giunte comunali, che dunque limiterebbe la libertà del sindaco nella scelta degli assessori (così C. cost n. 4 del 2010 e TAR Sicilia – Palermo n. 14310 del 2010).

Inoltre l’art. 1 del D. lgs. n. 198 del 2006 (codice delle pari opportunità) precisa che tale vincolo opera non solo per gli atti normativi o di carattere generale, ma anche nei confronti della intera attività dei soggetti pubblici e dunque anche per gli atti aventi contenuto politico, sebbene in assenza di una normativa intermedia dei regolamenti comunali.

A tal fine l’art. 6 del TUEL stabilisce che gli statuti comunali e provinciali devono contenere norme che assicurino le pari opportunità nelle giunte e negli organi collegiali, nonché negli enti e nelle aziende da essi dipendenti. Tale rinvio però non sarebbe una riserva ad una fonte normativa che subordina l’attuazione del principio, perché se così fosse sarebbe facilmente eludibile il citato art. 51 Cost.: nel silenzio degli Statuti gli enti locali sono comunque obbligati al rispetto del suddetto principio delle pari opportunità.

Compito del sindaco sarà dunque conseguire tale obiettivo e potendo essere sciolto da questo vincolo solo qualora riuscisse a provare di non aver potuto in concreto individuare un assessore di genere femminile. Non sarebbero motivazioni valide per eludere il vincolo quelle legate al rapporto fiduciario, che è un concetto di eccessiva estensione, non essenzialmente verificabile ed al quale si perviene solo al termine di un percorso di selezione. In ogni caso il sindaco resta il titolare ed il garante della linea politica della propria amministrazione e potrà in ogni momento revocare un assessore con il quale la collaborazione non sia più possibile, con il solo limite del divieto di comportamenti arbitrari.

 Maria Esmeralda Bucalo

Foto | Sito del Comune di Ghedi

Annunci
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196 risposte a [TAR Lombardia – Brescia sent. n. 1 del 5 gennaio 2012] Nelle giunte comunali deve essere garantita la rappresentanza di genere anche se non espressamente prevista dallo Statuto

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