&quot;Úřad evropského veřejného žalobce: Komparativní analýza s vybranými národními systémy prokuratury&quot;

Široký, Filip

The European Public Prosecutor's Office: Comparative Analysis with particular National Prosecution Systems Abstract: The European Public Prosecutor's Office provides not only a major breakthrough in the framework of European Criminal Law, but a revolutionary concept as a first cross-national prosecution system as well, including the non-European jurisdictions. Taking into account how sensitive is the matter of convergence of European Criminal Law for the Member States, as well as their endeavour to preserve sovereignty with regard to criminal policies, it is obvious, that there was not (and still is not) any agreement regarding the form, or even mere existence, of the EPPO. In my opinion, for the purposes of the EPPO's efficiency assessment, as well as alternatives of its particular aspects, it is most suitable to compare it with other existing prosecutions systems in chosen developed countries. Germany, France, USA and Japan were chosen as those countries, pursuant to the criteria of both Anglo-American and continental legal systems representation, the countries' GDP, geopolitical significance, the development of their legal systems in history, and the type of political establishment. In the first part of my thesis, I focus on analysing the aspects of the new office, its historical background and position...

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