Abstract and Keywords
In juvenile systems, countries vary considerably in how they define the jurisdiction of adult and juvenile courts and where they draw the lines between them. The starkest difference lies in the jurisdiction of the ages. This article provides an overview of current knowledge about national differences in juvenile justice systems. It describes formal structural differences between systems and provides brief depictions of systems representing importantly different models: the English juvenile court model with its heavy emphasis on crime reduction, the German youth criminal court model with its emphasis on social integration of young offenders, the Scandinavian non-juvenile-court model, and the New Zealand conferencing model. It reveals immediate outcomes in terms of the use of confinement and the frequency of transfers to adult courts. Finally, it makes an attempt to offer a number of observations about comparative advantages and disadvantages of different approaches.
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