Characteristics of Initiating Criminal Prosecution in England and France

Abstract

The given article concerns the characteristics of initiating criminal prosecution in England and France. Besides that, discussions
are held in the comparative legal context about initiating criminal prosecution in Georgia, France and England. Based on the comparison of procedural provisions of these countries the similarities and differences of initiating criminal prosecution have been distinguished. Furthermore, the article focuses on the range of bodies having an authority to initiate the prosecution. In the final part an evaluation is made whether it is appropriate to consider the elements of initiating prosecution of England and
France in the criminal procedure law of Georgia.