INSTITUTE OF JUSTICE IN VARIOUS COUNTRIES: COMPARATIVE LEGAL ANALYSIS
Abstract
This article examines the legal essence, regulatory frameworks, procedure for calculating criminal records, and mechanisms for their removal in the criminal law systems of four countries the Republic of Uzbekistan, Italy, Germany, and Australia through comparative legal analysis. Based on the fact that countries belong to different legal families, a comparative analysis of the institution of criminal record is carried out and conclusions and proposals for improving national legislation are presented..
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