Abstract
Before focusing on my own research into the role of the Cyprus Attorney General’s Office in prosecutions, in this chapter, a comparative description of prosecution systems in a number of other jurisdictions will be attempted, bearing in mind that “it is impossible to understand prosecution in one country or culture without seeing how it differs from prosecution elsewhere” (Johnson 2002, p. 89).
In the first section, the origins, constitutional position and organisation of prosecution services in three common law countries (England and Wales, Ireland and Northern Ireland), a mixed jurisdiction (Scotland), as well as a number of inquisitorial jurisdictions (mainly France, Germany and the Netherlands) will be described. The second section will deal with the role of the prosecuting authorities in investigations and the third one with the way different prosecution systems approach the issues of prosecutorial discretion, diversion from prosecution and the formulation of prosecution criteria and policies. This comparative analysis will not be constrained to a theoretical description of the systems; wherever empirical studies are available they will be cited, so that an insight into matters of practice, as well as principle, can be achieved. However, it has to be noted that, regrettably, empirical research studies in inquisitorial jurisdictions are significantly limited in comparison to the ones available in common law jurisdictions.2
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Notes
- 1.
- 2.
- 3.
Langbein (1973, p. 318) refers to the inherent fallacies of such a system: “The obvious drawback to any system of gratuitous citizen prosecution is that it is unreliable. There will be cases where there are no aggrieved citizens who survive to prosecute, and others where the aggrieved citizens will decline to prosecute, or be inept at it”.
- 4.
- 5.
Sanders refers to Hay’s (1983) analysis.
- 6.
See Edwards (1964).
- 7.
The British Section of the International Commission of Jurists.
- 8.
R v. Leighton, Lattimore and Salih (1975) 62 Crim. App. R. 53.
- 9.
But with considerably fewer powers than their Scottish counterpart, contrary to some of the suggestions heard in the Commission.
- 10.
The CPS was originally organised into 31 areas, which in most cases were built on existing prosecuting solicitors’ departments for each police force. In 1993 it was reorganised into 13 regions with strong control from the London headquarters but this was criticised by the Glidewell Report (Glidewell 1998) as a mistake which led to over-centralisation. In 1999 42 separate CPS areas were created, coextensive with the police areas, to facilitate the suggestion in the report that more decisions be taken locally rather than centrally. For a further discussion, see Ashworth (2000).
- 11.
Prosecution of Offences Act 1985, s. 1 (1) (b) (as initially enacted).
- 12.
With the exception of the prosecutions concerning some minor offences.
- 13.
House of Commons, Crown Prosecution Service, Fourth Report of the Home Affairs Committee, HMSO (London 1989).
- 14.
National Audit Office (1989).
- 15.
See Crown Prosecution Service’s Annual Reports and Discontinuance Surveys (Crown Prosecution Service 1993, 1994).
- 16.
However, in 2003–2004 the proportion of cases discontinued decreased to 13.8%, from 16.2% in 2001–2002. Ashworth and Redmayne (2005, pp. 193–196) argue that this is probably due to the changes brought by the Criminal Justice Act 2003 which transferred the authority to charge from the Police to the CPS.
- 17.
The Glidewell Report (1998) also expressed concern on this issue.
- 18.
- 19.
See a similar finding of the research by Hoyano et al. (1997). They found that in some cases prosecutors felt under pressure to continue a prosecution in serious cases even when the case was weak, especially where a decision not to prosecute might have resulted in public or press criticism.
- 20.
This is more problematic due to the prosecutors’ practice when reviewing the cases to rely mostly on police summaries, which proved to be very selective and sometimes misleading (Baldwin and Bedward 1991).
- 21.
- 22.
See the next section for a review of the gradual changes implemented as a result of recommendations of various commissions.
- 23.
E.g. the power of the DPP to issue guidance to custody officers as to how detained persons should be dealt with and as to what the police ought to do to facilitate the decisions on charge by prosecutors. The first edition of the DPP’s guidance was issued in May 2004 and the second one in January 2005.
- 24.
For a detailed analysis of the new legislation, see Brownlee (2004).
- 25.
In advance of the passing of the CJA 2003, a pilot statutory charging scheme had operated in five CPS areas to test Auld’s proposals. This scheme resulted in what was seen as a high level of success. The CPS reported that the benefits included a significant improvement in discontinuance rates and a reduction in the number of charges being dropped or changed (PA Consulting Group 2003).
- 26.
See Crown Prosecution Service’s Annual Report, 2005–2006.
- 27.
Prosecution of Offences Act (1974).
- 28.
The transfer of responsibility for the Local State Solicitor Service from the Attorney General to the DPP’s Office was completed in May 2007. See the Annual Report (2006) of the DPP’s Office.
- 29.
- 30.
The Working Party on Public Prosecutions reported that: (a) the prosecution of 98% of cases heard at a Magistrates’ Court were carried out by police officers; (b) police officers handled 93% of the cases in which the court committed an accused to a higher court of trial; (c) the remaining cases (mainly serious and particularly difficult cases, cases that have a political background and cases that involve a member of the Royal Ulster Constabulary) were dealt with by either a Crown Solicitor or a Crown Counsel; and (d) the ultimate responsibility for prosecutions rested with the Attorney General and in cases of a serious nature the relevant files had been referred to him for his directions and advice (Report of the Working Party on Public Prosecutions 1971).
- 31.
Report of the Advisory Committee on Police in Northern Ireland (1969).
- 32.
Report of the Working Party of Public Prosecutions (1971, para. 6).
- 33.
And, thus, the right to take over prosecutions being conducted by any other individual or agency.
- 34.
- 35.
It should be noted that the DPP had no formal involvement in the conduct of police investigations, prior to charge or summons, or between the charge and the submission to him of the police investigation file. It was, however, open to the police to seek the advice of the DPP’s staff in the course of their investigations, especially where it was apparent that complex issues of law or evidence were likely to be involved. The Director had also provided the police with detailed instructions on what should be included in an investigation file (Criminal Justice Review Group, Northern Ireland 2000).
- 36.
In the Review of the Criminal Justice System in Northern Ireland 2000 it is reported that in 1997 there were 1,128 prosecutions carried out by the DPP in the Crown Court, 7,262 by the DPP in magistrates’ courts and 27,209 by the RUC in the Magistrates’ Courts. Overall, 76% of cases were prosecuted by the police, including 79% of those in the magistrates’ courts.
- 37.
See the Annual Report (2007–2008) of the Public Prosecution Service for Northern Ireland.
- 38.
Prosecutors retain the right (previously possessed by the DPP) to request further investigation into any particular matter where it is considered that additional information is required in order to take a fully-informed prosecution decision. In addition, the Prosecution Service may require the Police Service of Northern Ireland to investigate any matter that comes to its attention where it believes that a criminal offence may have been committed.
- 39.
- 40.
See Sect. 2.2 of this chapter.
- 41.
For further analysis, see Sect. 2.2.
- 42.
- 43.
See Ambos (2000) for a more detailed comparative overview of the prosecutorial arrangements of various civil law countries (as well as common law countries).
- 44.
As Verrest (2000, p. 211) reports, “similar institutions have existed since the fourteenth century, but it is difficult to place the debut of the ministère public earlier than the beginning of the nineteenth century. At that time, the current ministère public received its main characteristics”.
- 45.
- 46.
Langbein (1974, p. 446) remarks that “(p)rior to that time, the prosecutorial function had been merged in the all-encompassing work of the inquisitorial judge, who both investigated alleged or suspected crime and then adjudicated on the basis of his own investigation”.
- 47.
For example, § 146 Law on the Constitution of the Judicial System in Germany states that prosecutors have to follow directives as issued by their superiors. According to this, the head of the public prosecution service, the Prosecutor-General, and also the Minister of Justice are authorised to direct and to supervise decisions made by individual prosecutors on criminal cases. Such directives can be issued as general guidelines but can also be related to individual cases.
- 48.
See Verrest (2000, pp. 212–213) for a more detailed description.
- 49.
See Parmentier et al. (2000), and Van Daele (2004) for a comprehensive review of the Belgian Prosecution Service.
- 50.
- 51.
However, in Germany the criminal justice system is organised on a federal basis and, thus, each of the 12 German States operates its own justice system headed by a different Minister of Justice.
- 52.
- 53.
See, however, an exception to this rule in the case of Norway, where in some particular minor cases the police have the responsibility for prosecutions (Jehle 2000).
- 54.
See, for example, Article 13 of the Dutch Police Act of 1993 which states that the police functions under the command of the public prosecution service and a prosecutor is entitled to give orders to the police in criminal matters that they are obliged to obey.
- 55.
See Sect. 2.2 of this chapter.
- 56.
Or the juge d’instruction in France.
- 57.
This is the so-called transactie system, which also applies to the prosecution level.
- 58.
There are very few empirical studies in continental jurisdictions with which to draw a better picture of the situation that exists in practice. See, however, Hodgson (2005) for a valuable contribution.
- 59.
Quoted in Krone (2003, p. 1).
- 60.
However, not entirely, as in many common law countries, including Ireland (and until very recently Northern Ireland) police still have a role in the prosecution of minor cases.
- 61.
Royal Commission on Criminal Procedure (1981, pp. 71–73).
- 62.
As Ashworth (1998, p. 173) remarks on the pre-Criminal Justice Act 2003 situation: “The English prosecutor has no power to order the police to interview different people, or to ask further questions of the defendant or other witnesses. The CPS may put a request to the police for further investigations, but it seems that in the past this has sometimes been a source of friction between the two organisations”.
- 63.
Field (1994, p. 121) comments on the Commission’s approach: “The report complained that no foreign model existed in which the rights and interests of the various parties were so well balanced that it could simply be adopted… The idea that foreign experience might cast light on the kind of underlying principles needed for designing systems is not considered by the Commission”.
- 64.
- 65.
In Northern Ireland, as shown earlier, the DPP had some indirect investigatory powers. See Articles 6(3) and 5(1)(b) of the Prosecution of Offences Order.
- 66.
See Law Reform Commission of Canada (1990) and Stenning (1986).
- 67.
- 68.
McConville et al. (1991).
- 69.
- 70.
Leng (1993).
- 71.
However, in many countries special offices were created long ago who were dealing with economic crime; for example, the Serious Fraud Office was established under the Criminal Justice Act 1987 (UK) and combined in one office the roles of investigator and prosecutor. See also the Criminal Assets Bureau in the Republic of Ireland and the Integrated Proceeds of Crime (IPOC) Units in the Canadian Federal jurisdiction.
- 72.
“All sites report that the co-location of Police and CPS staff is eliminating unnecessary work through improved communications. Enquiries by CPS and the Police which used to take weeks to clear can now be resolved satisfactorily in minutes. Speedier notification of proposed discontinuance, for example, has reduced the wasted effort on upgrading files unnecessarily” (Glidewell Working Group 2001, p. 7).
- 73.
Decisions about the cases were taken jointly only after the completion of the police investigation and, most of the time, after the charging decision.
- 74.
- 75.
See Elsner (2005).
- 76.
See, however, the Law on Control of Organised Crime of 1992 by which the police have been authorised to initiate deployment of undercover agents and have also been authorised to make independent decisions in emergency cases.
- 77.
Apart from the mentioned inefficiencies, see also criticisms of the limited defence rights during investigations (Hodgson 2004). However, in an attempt to demonstrate conformity with the ECHR and under the influence of the Recommendations of the Council of Europe (e.g. Rec 97(13)), there are a series of reforms in inquisitorial countries aiming to strengthen the defence’s position. See Field and West (2003) and Hodgson (2005) for a review of relevant reforms introduced in France.
- 78.
See evidence presented in Bryett and Osborne (2000).
- 79.
- 80.
See Goldstein and Marcus (1977) and the discussions in the RCCJ 1993.
- 81.
- 82.
As Langbein (1974, p. 440) remarks: “(t)he prosecutor’s power of non-prosecution becomes controversial when it extends beyond the power to discard hopeless cases. Prosecutorial discretion … means the power to decline to prosecute in cases of provable criminal liability”.
- 83.
See Ashworth and Redmayne (2005, p. 165).
- 84.
- 85.
Especially in relation to adult cases, as the same authors report.
- 86.
With the exception of Italy, which theoretically still adopts the principle of strict legality. See, however (Di Federico 1998, p. 378): “The first clear element that emerges from our research is that, in spite of the constitutional provisions that require our magistrates to prosecute all criminal violations, penal action in Italy is de facto just as discretionary as in other countries, and perhaps more”.
- 87.
Ashworth and Redmayne (2005, p. 147) mention another important reason for this trend, naming the “increasing realisation that prosecution and sentence in court are stressful for all participants and are not necessarily more effective (in terms of reconviction rates) than forms of diversion”.
- 88.
There has been criticism by some scholars in Germany that conditional dismissals enable rich suspects to buy their way out of criminal prosecution. See inter alia Jehle (2003).
- 89.
- 90.
- 91.
This is not necessarily the same in all expedience-based systems. See, for example, the situation in the Netherlands where prosecution policy is “strikingly organised and determinate, implementing a carefully considered and coherent working philosophy” (Fionda 1995, p. 63).
- 92.
Contrary to the situation in Scotland, where for a long time now there has been a sophisticated diversionary package available to the procurators fiscal, including fiscal warnings, conditional offers of fixed penalties, fiscal fines and diversionary schemes (e.g. supervision by a social worker, referral to drug treatment, restorative interventions).
- 93.
- 94.
- 95.
See Ashworth and Redmayne (2005, p. 148): “In the heavily pragmatic English system, fundamental values and principles have little explicit recognition, even as starting points. Instead, the alternatives to prosecution have developed one by one, often without statutory foundations, and hardly constitute a ‘system’ of diversion”.
- 96.
In Scotland there is also a Prosecution Code which sets out the criteria for decision-making and the range of options available to prosecutors dealing with reports of crime.
- 97.
Furthermore, the law on which prosecutors base the exercise of their discretion is also relatively detailed.
- 98.
Ashworth (1998) reports that, in 1994, the Home Secretary announced a new policy on police cautioning followed by a new circular directed to the police requiring them to change their cautioning policies. In the 1994 edition of the Code for Crown Prosecutors, the influence of this policy was more than obvious: “… this episode casts doubt on the CPS’s claim to be independent and quasi-judicial, and raises questions about the role of the Attorney General, a member of the government and the minister to whom the Director of Public Prosecutions is accountable” (Ashworth 1998, p. 196). See also Ashworth and Fionda (1994) and a response to this criticism by Daw (1994).
- 99.
See a series of Recommendations issued by the Council of Europe relating to prosecutions: Rec (2000) 19, Rec (97) 13, Rec (92) 17, Rec (95) 12, etc. See also the recent Opinions of the Consultative Council of European Prosecutors (CCPE) “Alternatives to prosecution” – Opinion No 2 (2008) and “The Role of prosecution services outside the Criminal Law Field” – Opinion No 3 (2008).
References
Ambos K (2000) The Status, Role and Accountability of the Prosecutor of the International Criminal Court: A Comparative Overview on the Basis of 33 National Reports. Eur J Crime Crim Law Crim Justice 8(2):89
Ashworth A (1987) The “Public Interest” Element in Prosecutions. Crim Law Rev 1987:595
Ashworth A (1998) The Criminal Process: An Evaluative Study, 2nd edn. Oxford University Press, Oxford
Ashworth A (2000) Developments in the Public Prosecutor’s Office in England and Wales. Eur J Crime Crim Law Crim Justice 2000:257
Ashworth A, Fionda J (1994) The New Code for Crown Prosecutors: Prosecution, Accountability and the Public Interest. Crim Law Rev 1994:894
Ashworth A, Redmayne M (2005) The Criminal Process, 3rd edn. Oxford University Press, Oxford
Auld RE (2001) Review of the Criminal Courts of England and Wales: Report. The Lord Chancellor’s Department, London
Baldwin J (1997) Understanding Judge Ordered and Directed Acquittals in the Crown Court. Crim Law Rev 1997:536
Baldwin J, Bedward J (1991) Summarising Tape Recordings of Police Interviews. Crim Law Rev 1991:671
Baldwin J, Hunt A (1998) Prosecutors Advising in Police Stations. Crim Law Rev 1998:521
Bell RE (1989) The Office of Director of Public Prosecutions for Northern Ireland. Unpublished thesis, Queen’s University, Belfast
Belloni F, Hodgson J (2000) Criminal Injustice: An Evaluation of the Criminal Justice Process in Britain. Macmillan, London
Bennion F (1986) The New Prosecution Arrangements (1) The Crown Prosecution Service. Crim Law Rev 1986:3
Brownlee ID (2004) The Statutory Charging Scheme in England and Wales: Towards a Unified Prosecution System. Crim Law Rev 2004:869
Bryett K, Osborne P (2000) Criminal prosecution procedure and practice: international perspectives, Northern Ireland, Criminal Justice Review Group Research Report 16. Stationery Office, Belfast
Cappelletti M (1984) The Judicial Process in a Comparative Perspective. Clarendon, Oxford
PA Consulting Group (2003) Charging Suspects: Early Involvement by the CPS: A Pilot Report. http://www.cps.gov.uk
Cretney A, Davis G (1995) Punishing Violence. Routledge, London
Crisp D, Moxon D (1994) Case Screening by The Crown Prosecution Service: How and Why Cases are Terminated, Research Study no 137. HMSO, London
Crisp D, Whittaker C, Harris J (1995) Public Interest Case Assessment Schemes, Home Office Research Study 138. HMSO, London
Daw KR (1994) The New Code for Crown Prosecutors: A Response. Crim Law Rev 1994:904
De Doelder H (2000) The Public Prosecution Service in the Netherlands. Eur J Crime Crim Law Crim Justice 2000:187
Di Federico G (1998) Prosecutorial Independence and the Democratic Requirement of AccountAbility in Italy: Analysis of a Deviant Case in a Comparative Perspective. Br J Criminol 38:371
Duff P (1997) Diversion from Prosecution into Psychiatric Care: Who Controls the Gates? Br J Criminol 37:15
Duff P (1999) The Prosecution Service: Independence and Accountability. In: Duff P, Hutton N (eds) Criminal Justice in Scotland. Ashgate, Aldershot
Duff P, Burman M (1994) Diversion from Prosecution to Psychiatric Care. Scottish Office Central Research Unit, Edinburgh
Edwards JL (1964) Law Officers of the Crown: A Study of the Offices of Attorney-General and Solicitor-General of England with an account of the Office of the Director of Public Prosecutions of England. Sweet and Maxwell, London
Elsner B (2005) Police Function Within the Criminal Justice System. Talk at the conference “The Growing Importance of the Public Prosecution Service: Best European Practices in the Face of Heightened Crime Rates”, Georg-August University Gottingen, Germany, 6–8 October 2005
Falletti F (2004) The French Prosecution Service. In: Tak JP (ed) Tasks and Powers of the Prosecution Services in the EU Member States, vol I. Wolf, Nijmegen
Field S (1994) Judicial Supervision and the Pre-Trial Process. J Law Soc 21(1):119
Field S, Alldridge P, Jorg N (1995) Prosecutors, Examining Judges, and Control of Police Investigations. In Fennel P, Harding C, Jorg N, Sward B (eds) Criminal Justice in Europe: A Comparative Study, Oxford: Clarendon Press
Field S, West A (2003) Dialogue and the Inquisitorial Tradition: French Defence Lawyers in the Pre-Trial Criminal Process. Crim Law Forum 14:261
Fionda J (1995) Public Prosecutors and Discretion: A Comparative Study. Clarendon, Oxford
Gelsthorpe L, Giller H (1990) More Justice for Juveniles: Does More Mean Better? Crim Law Rev 1990:153
Glidewell I (1998) Review of the Crown Prosecution Service: A Report, Cmnd. 3960. The Stationery Office, London
Goldstein A, Marcus M (1977) The Myth of Judicial Supervision in Three “Inquisitorial” Systems: France, Italy and Germany. Yale Law J 87:240
Gordon P (1980) Policing in Scotland. SCCL, Glasgow
Hay D (1983) Controlling the English Prosecutor. Osgoode Hall Law J 21(2):175
Hetherington T (1989) Prosecution and the Public Interest. Waterlow, London
Hodgson J (2001) The Police, The Prosecutor And The Juge D’Instruction. Judicial Supervision in France, Theory and Practice. Br J Criminol 41:342
Hodgson J (2004) The Detention and Interrogation of Suspects in Police Custody in France. Eur J Criminol 1(2):163
Hodgson J (2005) French Criminal Justice: A Comparative Account of the Investigation and Prosecution of Crime in France. Hart, Oxford
Hoyano A, Hoyano L, Davis G, Goldie S (1997) A study of the impact of the Revised Code for the Crown Prosecutors. Crim Law Rev 1997:556
Hoyle C (1998) Negotiating domestic violence: police, criminal justice, and victims. Clarendon, Oxford
Jehle J (2000) Prosecution in Europe: Varying Structures, Convergent Trends. Eur J Crim Policy Res 8:27
Jehle J (2003) Criminal Justice in Germany 2003. Federal Ministry of Justice, Berlin
Jehle J, Wade M (2006) Coping with Overloaded Criminal Justice Systems: The Rise of Prosecutorial Power Across Europe. Springer, Berlin
Johnson DT (2002) The Japanese Way of Justice: Prosecuting Crime in Japan. Oxford University Press, New York
Krone T (2003) The Limits of Prosecution Authority. Paper Presented at Regulatory Institutions Network (RegNet), Australian National University, 18 November 2003
Langbein JH (1973) The Origins of Public Prosecution at Common Law. Am J Leg Hist 27:313
Langbein JH (1974) Controlling Prosecutorial Discretion in Germany. Univ Chic Law Rev 41:439
Leigh LH, Hall Williams JE (1981) The Management of the Prosecution Process in Denmark, Sweden and the Netherlands. James Hall, Leamington Spa
Leigh L, Zedner L (1992) A Report on the Administration of Justice in the Pre-trial Phase in France and Germany, Royal Commission on Criminal Justice Research Study No. 1. HMSO, London
Leng R (1993) The Right to Silence in Police Interrogation: A Study of the Issues Underlying the Debate, Royal Commission on Criminal Justice Research Study No.10. HMSO, London
Leng R, McConville M, Sanders A (1996) Researching the Discretion to Charge and to Prosecute. In: Sanders A (ed) Prosecution in Common Law Jurisdictions. Aldershot, Dartmouth
Lewis C (2006) The Prosecution Service Function within the English Criminal Justice System. In: Jehle J, Wade M (eds) Coping with overloaded Criminal Justice Systems: The Rise of Prosecutorial Power Across Europe. Springer, Berlin
Lidstone K (1987) The Reformed Prosecution Process in England: A Radical Reform? Crim Law J 11:296
Little RK (1999) Proportionality as an Ethical Precept for Prosecutors in their Investigative Role. Fordham Law Rev 68:723
Mansfield G, Peay J (1987) The Director of Public Prosecutions: Principles and Practices for the Crown Prosecutor. Tavistock, London
McConville M, Wilson G (eds) (2002) The Handbook of the Criminal Justice Process. Oxford University Press, Oxford
McConville M, Sanders A, Leng R (1991) The Case for the Prosecution. Routledge, London
Moody SR, Tombs J (1982) Prosecution in the Public Interest. Scottish Academic Press, Edinburgh
Narey M (1997) Review of Delay in the Criminal Justice System: A Report (“the Narey Report”). Home Office, London
Office of the Director of Public Prosecutions (2007) Annual Report 2007. http://www.dppireland.ie
Osborne, P (1997) The control of the discretion to prosecute in Ireland. Unpublished thesis, Queen’s University, Belfast
Public Prosecution System Study Group (1999) (Chair: Dermot Nally) Report of the Public Prosecution System Study Group. http://www.dppireland.ie/filestore/documents/Report_of_ the_Public_Prosecution_System_Study_Group.pdf
Rose D (1996) In the Name of the Law. Jonathan Cape, London
Sanders A (1986a) Arrest, Charge and Prosecution. Leg Stud 6(3):257
Sanders A (1988a) Incorporating the “public interest” element in the decision to prosecute. In: Hall Williams JE (ed) The Role of the Prosecutor. Gower, Aldershot
Sanders A (1996) Introduction. In: Sanders A (ed) Prosecution in Common Law Jurisdictions. Dartmouth, Aldershot and Brookfield, USA
Sanders A (2004) Prosecutions in England and Wales. In: Tak JP (ed) Tasks and Powers of the Prosecution Services in the EU Member States, vol I. Wolf, Nijmegen
Sanders A, Young R (1994) The Rule of Law, Due Process and Pre-Trial Criminal Justice. Curr Leg Probl 47:125
Sanders A, Young R (2000) Criminal Justice. Butterworths, London
Sanders A, Young R (2002) From Suspect to Trial. In: Maguire M, Morgan R, Reiner R (eds) The Oxford Handbook of Criminology. Oxford University Press, Oxford
Schwimmer MW (2000) Opening Speech. In: Pan-European Conference: What Public Prosecution Service in Europe in the 21st century? Strasburg, 22–24 May 2000
Stedward G, Millar A (1989) Diversion from Prosecution (Central Research Unit Papers). The Stationery Office Books, Edinburgh
Stenning PC (1986) Appearing for the Crown: A legal and historical review of criminal prosecutorial authority in Canada. Brown, Cowansville
Tak JP (2004a) Introduction. In: Tak JP (ed) Tasks and Powers of the Prosecution Services in the EU Member States, vol I. Wolf, Nijmegen
Tak JP (2004b) The Dutch Prosecution Service. In: Tak JP (ed) Tasks and Powers of the Prosecution Services in the EU Member States, vol I. Wolf, Nijmegen
Tak JP (ed) (2005a) Tasks and Powers of the Prosecution Services in the EU Member States, vol II. Wolf, Nijmegen
Van Daele D (2004) The Belgian Prosecution Service. In: Tak JP (ed) Tasks and Powers of the Prosecution Services in the EU Member States, vol I. Wolf, Nijmegen
Verrest P (2000) The French Public Prosecution Service. Eur J Crime Crim Law Crim Justice 8(3):210
Wade M (2005) The Changing Role of European Prosecution. Eur Soc Criminol Newsl 4(2):3
Walsh D (2004) Public Prosecutors in Ireland. In: Tak JP (ed) Tasks and Powers of the Prosecution Services in the EU Member States, vol I. Wolf, Nijmegen
Walther S (2000) The Position and Structure of the Prosecutor’s Office in the United States. Eur J Crime Crim Law Crim Justice 2000:283
Weigend T (2004) The Prosecution Service in the German Administration of Criminal Justice. In: Tak JP (ed) Tasks and Powers of the Prosecution Services in the EU Member States, vol I. Wolf, Nijmegen
Zimring NE, Johnson DT (2005) On the Comparative Study of Corruption. The British Journal of Criminology 45(6): 793–809
National Audit Office (1989) Review of the Crown Prosecution Service, Report by the Controller and the Auditor General, HC 345. HMSO, London
Hodgson J (2002) Hierarchy, Bureaucracy and Ideology in French Criminal Justice: some Empirical Observations. J Law and Soc 29(2):227–257
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Kyprianou, D. (2010). Comparative Analysis of Prosecution Systems. In: The Role of the Cyprus Attorney General's Office in Prosecutions: Rhetoric, Ideology and Practice. Springer, Berlin, Heidelberg. https://doi.org/10.1007/978-3-642-01921-0_2
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