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The Structure of Criminal Procedure: Laws and Practice of France, Soviet Union, China, and the United States ...
Barton L. Ingraham
Greenwood Press
, 1987 - 212 pages
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"A model is developed for analyzing
criminal procedure
across nations and cultures, and applied to the U.S.,
France
, the U.S.S.R. and
China
. The model envisions common functions of arrest and detention, screening, charging and defending, trial, sanctioning and appeal. The comparison reveals significant differences between inquisitorial and adversarial systems, including the extent of court authority to control other criminal justice agencies, the defendant's role in the proceedings, and the court's role in the proceedings. Differences between noncommunist and communist inquisitorial systems involve personnel who perform each function, degrees of public participation, and the educative-rehabilitative function of the criminal justice process." Criminal Justice Abstracts
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