Foreign experience in organizing the activities of investigative bodies according to the three-tier model of criminal justice

Abstract

Relevance. The relevance of the study was the need to develop theoretical ideas about the three-tier model of criminal justice in the Republic of Kazakhstan, taking into account legislative innovations from 2021 and the implementation of foreign experience in this area. Purpose. The purpose of the study was to study the features of the activities of the investigative bodies according to the three-tier model of criminal justice in the Republic of Kazakhstan and other countries (Germany, France, Italy). Methodology. The article used methods of statistical analysis, analogy and generalization, as well as comparative legal, formal legal and formal logical approaches. Results. The study revealed the features of the legal regulation of the three-tier model of criminal proceedings under the laws of the Republic of Kazakhstan and other countries. It was stated that each country, when regulating, proceeded from its national interests. It is stated that the three-tier model includes the investigative, judicial and prosecutorial links, each of which performs certain functions and has its own powers in the framework of the criminal process. Conclusions. The paper analyses the features and principles of functioning of each link � investigative, judicial and prosecutorial, and their relationship within the framework of the criminal process. The findings will help to better understand the organization of criminal proceedings in the Republic of Kazakhstan and may be useful for the development and improvement of the country�s criminal law system. Keywords: prosecutor; court; investigator; interaction; Criminal procedure Code