oa Comparative and International Law Journal of Southern Africa - The uniform approach to participation in criminal law: a comparative study of Italian and American law
There are two approaches according to which the criminal liability of a number of persons involved in the commission of the same crime can be judged. On the one hand, there is the uniform or undifferentiated approach: all persons who participated in a criminal action are said to be liable on the same basis. On the other hand a differentiated approach to participation is followed according to which a conceptual distinction is drawn between principals and accessories.
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