Its civil service system, at the same time, is decentralized as every region/province has covered services that vary by their need (Wisler & Onwudiwe, 2008). In this manner, the French provinces get the advantages of a centralized regime while maintaining a certain amount of independence. In general, the criminal justice system of France is rooted in the Roman legal institution referred to as civil law (Dammer & Albanese, 2013). Malaysia The Malaysian legal system was adopted from the English system following the introduction of the Royal Charter of Justice in Penang on March 25th, 1807 under the auspices of the EIC – a then Indian Administrative Firm (Wisler & Onwudiwe, 2008).
The criminal justice system of Malaysia came years of hard experience of trying to control crime, which finally came to succeed with the help of Britain; as does its legal system which went together with the evolvement of its criminal justice system (Dammer & Albanese, 2013). Overview of the Country’s Criminal Justice System This next section will provide an overview of self-defense, criminal responsibility, crime definitions and search and seizure of the three countries. The United States The right to self-defense grants people the right to prevent or stop violence or force towards them by applying a reasonable level of violence or force (Dammer & Albanese, 2013).
As a basic rule, self-defense simply defends the application of force when it is applied in reply to an abrupt danger (Wisler & Onwudiwe, 2008). The danger can be verbal, on condition that it puts the intended party in an instant fear of physical threat (DuPont-Morales et al. , 2007). With regards to criminal responsibility, under article 32 of the United States criminal code, a man or woman who has reached the age of 12 shall be liable of criminal liability before a crime commission.
Before the age of 12, it is regarded as the primary responsibility of the parent, or guardian to build the code of conduct of the child (Wisler & Onwudiwe, 2008). The U. S. Fourth Amendment grants that the right of individuals to be secure in their persons, papers houses and effects, against perverse searches and seizures, shall not be dishonored or no warrants shall be issued (Wisler & Onwudiwe, 2008).
However, upon probable cause, supported by affirmation or oath, and specifically describing the area to be searched, as well as the things or individuals to be seized, the law enforcement can go ahead and search the property (DuPont-Morales et al. , 2007).
Dammer, H. R., & Albanese, J. S. (2013). Comparative criminal justice systems. London: Cengage Learning.
DuPont-Morales, M. A., Hooper, M. K., & Schmidt, J. (2007). Handbook of criminal justice administration (4th ed.). New York: Marcel Dekker Publishers.
Hassan, M., & Haji, A. (2014). The administration of criminal justice in Malaysia: The role and function of prosecution. Retrieved from http://www.unafei.or.jp/english/pdf/RS_No53/No53_25PA_Hassan.pdf
Hopson, J. (2012). Breaking the blue wall: One mans war against police corruption. New York: Oxford University Press.
Reichel, P. L. (2005). Comparative Criminal Justice Systems (4th Ed.). Upper Saddle River, New Jersey: Pearson.
U.S. Commission on Civil Rights. (USCCR). (2014). Recruitment, selection, and training for police work. Retrieved from http://www.usccr.gov/pubs/guard/ch2.htm
Wisler, D., & Onwudiwe, I. D. (2008). Community policing in comparison. Police Quarterly, 11(4), 427-446.