Homicide Law in Comparative Perspective (repost)
Homicide Law in Comparative Perspective (Criminal Law Library) by Jeremy Horder
English | December 2007 | ISBN-10: 1841136964 | 239 pages | PDF | 1,8 MB
English | December 2007 | ISBN-10: 1841136964 | 239 pages | PDF | 1,8 MB
A number of jurisdictions world-wide have changed or are considering changing their homicide laws. Important changes have now been recommended for England and Wales, and these changes are an important focus in the book, which brings together leading experts from jurisdictions across the globe (England and Wales; France; Germany; Scotland; Australia; The United States of America; Canada; Singapore and Malaysia) to examine key aspects of the law of homicide. Key areas examined include the structure of the law of homicide and the meaning of fault elements. For example, the definition of murder, or its equivalent, is very different in France and Germany from the definition used in England and Wales. French law, like the law in a number of American states, ties the definition of murder to the presence or absence of premeditation, unlike the law in England and Wales. Unlike most other jurisdictions, German law makes the killer's motive, such as a sadistic sexual motive, relevant to whether or not he or she committed the worst kind of homicide.