Introduction

This introduction presents an overview of the key concepts discussed in the subsequent chapters of this book. The book concerns the question of whether the Coroners and Justice Act 2009 delivers the reform. It deals with the question from a domestic point of view which already includes some comparative aspects. The book outlines the major issues of some foreign jurisdictions. The collection starts with by Catherine Elliott, A Comparative Analysis of English and French Defences to Demonstrate the Limitations of the Concept of Loss of Control. The book compares the test of 'diminished responsibility' under the Coroners and Justice Act 2009 with the equivalent criteria, including understanding and self-control, in Islamic jurisprudence. It then proposes to critically review and comparatively assess the dispositions of the Code Pénal in order to consider whether the Coroners and Justice Act 2009 should be considered as a model to follow.