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
|Article Title||The uniform approach to participation in criminal law: a comparative study of Italian and American law|
|© Publisher:||Institute of Foreign and Comparative Law|
|Journal||Comparative and International Law Journal of Southern Africa|
|Publication Date||Nov 1971|
|Pages||218 - 292|
|Keyword(s)||Accessories, Comparative study, Criminal law, Italian Criminal Code, Italian Criminal law, Liability, Model Penal Code, Principals, South Africa and United States of America|
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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