COMPARATIVE APPROACH TO JUVENILE JUSTICE

Апстракт

In this paper, the characteristics of criminal legislation for children in several states are presented and
analysed in order to become familiar with their criminal justice systems. On this regard, emphasis is
given to the comparative approach of juvenile justice by comparing criminal legislations of some
states, such as the juvenile justice of the Republic of North Macedonia, the Republic of Kosovo, the
Republic of Albania, the Republic of Croatia, the Netherlands, the Swiss Confederation, Norway,
England and Wales, with reference to the following comparative elements: (1) the minimum age of
children; (2) minimum age for criminal responsibility of children; and (3) minimum age for the
imposition of sentences on children and reaching adulthood; Such comparisons are additionally
illustrated in tabular form in order to provide a comprehensible picture to the reader regarding the
aforementioned comparisons. Also, in this regard, the three main models of legal-penal treatment of
children in different states have been discussed and clarified