JURY TRIAL IN CRIMINAL CASES IN RUSSIA, ENGLAND AND FRANCE: A COMPARATIVE ANALYSIS OF KEY DIFFERENCES AND SIMILARITIES

Abstract

The article provides a comparative analysis of the institute of jury trial in criminal cases in Russia, England and France, with a focus on their legal foundations, rights and duties of jurors, as well as their influence on the outcome of trials. Historical aspects of jury trial formation in each of the countries and peculiarities of modern application of this institution are considered. Special attention is paid to the differences in procedural approaches: in Russia jurors participate in the discussion of guilt, but the final decision rests with the judge, while in England and France jurors have equal rights with professional judges in reaching a verdict. In addition, the different procedures for jury composition and the ways in which decisions are made, including voting and the influence of juries on sentencing, are analyzed. The article identifies similarities and differences in the functioning of the jury trial, which allows for a better understanding of its role in the legal systems of the three countries.