A Comparative Look at the Roles and Functions of the Prosecution and Defense in Western Trail Systems

Inquisitorial Traditions at International Criminal Tribunals ......... 545 16.10 Conclusions ........................................................................................ 548 References ...................................................................................................... 549

In discussing criminal trial traditions, legal scholars often distinguish trials that take place in countries within the common law tradition and those that take place in countries that have a legal system based on the civil law tradition. Common law countries include the major English-speaking coun-

tries such as the United States, Canada, England, and Australia. Continental countries such as France, Germany, the Netherlands, and Denmark share the civil law tradition.