France today formally protested U.S. criticism of its decision to release Palestinian terrorist leader Abu Daoud, saying the criticism "constituted an inadmissible comment on the French courts."

In a meeting today with American Charge d'Affaires Samuel Gammon, the French Foreign Ministry's director of American affairs, Jaques de Folin, expressed "surprise" over a U.S. State Department spokesman's comment Tuesday expressing "dismay" over France's willingness to release Abu Daoud on "an apparent legal technicality" rather than listen to Isareli and West German requests for extradition.

The Tuesday release of the Black September operations leader, who was arrested here last Friday, has touched off a storm of Israeli and international protest.

Washington Post correspondent Michael Getler reported from Bonn that West Germany stepped up its criticism of the release today. A senior West German Justice Ministry official accused France of ignoring past practice on extraditions and using a "purely formal" technicality to reject West Germany's request that Abu Daoud be held for an extradition hearing.

The 39-year-old Palestinian, whose real name is Mohammed Daoud Audeh, is suspected of having been one of the planners of the 1972 terrorist attack on the Israeli Olympic team in Munich, in which 11 Israeli athletes and five terrorists were killed.

French officials have said that the West German police requested Abu Daoud's arrest in a telephone conversation with agents of the French counter-espionage agency, known by its initials as the DST. Abu Daoud, who traveled on an Iraqi passport under an assumed name, indicated in court Tuesday that he had been given a promise of immunity from arrest, presumably by the French Foreign Ministry, when he received his visa in Beirut.

A Foreign Ministry statement issued late yesterday noted that the Court of Appeals that heard Abu Daoud's request to be freed had ruled that he had been illegally arrested and could not continue to be held. But France has not commented on the contention that the Palestinian may have been promised immunity.

He was received as part of a Palestine Liberation Organization delegation at the Foreign Ministry Friday morning. The delegation had been given visas to attend the funeral here of a slain Palestinian militant.

Meanwhile, in Washington, a letter signed by 38 U.S. Senators, was sent to the French ambassador to the United States today protesting Abu Daoud's release.

Sen. Floyd Haskell (D-Colo.), who circulated the letter, said that it told French Ambassador Jacques Kosciusko-Morizet that, "we feel compelled to convey our sense of the injustice of the release of Abu Daoud. His release can only be interpreted as a severe setback in the fight against terrorism."

The ambassador was asked to convey "our very deep dissatisfaction and dismay at this action to your government."

Rep. Andrew Maguire (D-N.J.) and five other House members are scheduled to meet with the French ambassador Tuesday to protest Abu Daoud's release.