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Books > Law > Laws of other jurisdictions & general law > Criminal law
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Homicide Law in Comparative Perspective (Hardcover, Uk Ed.)
Loot Price: R3,057
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Homicide Law in Comparative Perspective (Hardcover, Uk Ed.)
Series: Criminal Law Library
Expected to ship within 12 - 17 working days
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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. England and Wales is in a
minority of English-speaking jurisdictions in that it does not
employ the concept of 'wicked' recklessness, or of extreme
indifference, as a fault element in homicide. Understanding these
often subtle differences between the approaches of different
jurisdictions to the definition of homicide is an essential aspect
of the law reform process, and of legal study and scholarship in
the criminal law. Every jurisdiction tries to learn from the
experience of others, and this book seeks to make a contribution to
that process, as well as providing a lively and informative
resource for scholars and students.
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