Vol. 21 No. 1 (2018): Procedural Cultures: The Plea Bargaining
The core of this debate takes us to the world of comparative law and invites us to reflect on the influences and relationships between different systems in the field of criminal procedural law. The recent adversarial reforms implemented in continental European and Latin American procedural systems suggest an “Americanization” of the criminal process in these countries. However, the author intends to refute this idea through an analysis of the way in which the American institute of plea bargaining has been introduced in four representative jurisdictions of the continental European and Latin American tradition.