Comparative Survey of Criminal Investigation Systems in Asia: Best Practices and Challenges

Abstract

 

This article comparatively reflects on prevailing legal frameworks and practices of investigation within criminal justice system, and the roles of investigator and prosecution in Asia countries, including Nepal, India, China, Japan and Sri Lanka, appraising their systems in terms of both best practices and challenges. It also draws descriptions and comparisons on the issue under consideration from western countries including the USA, the UK and Germany, which have been consequential in the development of criminal justice system of the discussed Asian countries.

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