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With respect to criminal procedure, certain civil law systems are based upon a variant of the inquisitorial system rather than the adversarial system. In common law countries, this kind of judicial organization is sometimes criticized as lacking a presumption of innocence Most European countries, however, are parties to the European Convention on Human Rights (ECHR) adopted under the auspices of the Council of Europe in 1950 to protect human rights and fundamental freedoms. Article 6 of the ECHR guarantees “the right to a fair trial” and the presumption of innocence. Some Civil law nations also have legislation that predates the Convention and secures the … Read More...

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and many other generally English-speaking countries or Commonwealth countries (except the UK’s Scotland , which is bijuridicial , and Malta ). Essentially, every country that was colonised at some time by England, Great Britain, or the United Kingdom uses common law except those that were formerly colonised by other nations, such as Quebec (which follows the law of France in part), South Africa and Sri Lanka (which follow Roman Dutch law ), where the prior civil law system was retained to respect the civil rights of the local colonists. Guyana and Saint Lucia have mixed Common Law and Civil Law systems.

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