The dissertation deals with the comparison of criminal justice systems in Taiwan and China. It deals with the question of how the two systems are compared and what similarities and differences they have. Both systems have similarities, as both are based on civil law, but there are also differences. Both systems have problems with trust and confidence, which they have tried to solve with several reforms, but neither were successful. Both systems also have the death penalty, but differ in the number and method of executions. The Chinese system does not have as much independence as the judiciary in the Taiwanese system, which poses certain limitations. The Chinese system uses a lay assessor system, where lay people are used as lay assessors in the trial. While they do not have such a system in Taiwan, they have been trying to introduce it for many years. By introducing such a system, they want to improve confidence and trust in the system. The roles of the judiciary, police and prosecutors are also comparable. But differences occur in the trial process. In both systems, elements of the adversarial system were added to the traditional inquisitorial model of trial, which partially changed the role of trial participants and shifted the burden of proof of guilt onto the prosecutor. This also gave lawyers a bigger role in the trial. Lawyers, however, have a much worse position in China, as they are very limited in what they can do and which cases they can take. Chinese judges are also limited, since in serious cases, the final decision is in the hand of the Adjudication Committee . The Chinese police have more power than the police officers in Taiwan, and they also have poorer working conditions and poorer training.
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