ABSTRACT
Exercises in comparative criminology are relatively rare, especially in the European context. David Nelken (2002) has indicated the difficulties of understanding and explanation, even in a seemingly straightforward area like policy research. There is no field unaffected by the specifics of history, culture, legal tradition and politics. Similarities in such things, as well as a common language, have meant that both comparisons and policy borrowings have flowed abundantly from west to east between America and Britain, with further influences from other parts of the Anglo-Saxon world, especially Australia and New Zealand (Jones and Newburn 2002). Recently, observers have perceived some harsher aspects of crime control associated with ‘the Anglo-Saxon model’ penetrating European jurisdictions, usually in conjunction with a rightward political drift (van Swaaningen 1997 2005; Tham 2001; Nelken 2002).
