დანაშაულში თანამონაწილეობის სამართლებრივი ბუნება აშშ-ის სისხლის სამართალში

Abstract

Comparative criminal law is a stage in the development of national criminal law. In view of the fact that national legislations are very different and changing, it is very important and necessary to consider legal problematics from their comparative and legal perspective. Modern integration processes and the deepening of mutual cooperation with foreign academic centres make it relevant to learn about the legislation of different legal systems, especially in the areas of relations between states, such as criminal liability and punishment. A significant part of this article is dedicated to comparative and systematic methods. The provisions adopted in the common law system are compared with a respective legal position of continental Europe from the perspective of a comparative and legal approach. Based on that, a respective conclusion is suggested taking into consideration achievements in academic research, legislation and practice.