The outbreak of the SARS-CoV-2 virus has reinvigorated the question of the criminal law aspects of transmitting infectious diseases. This master's thesis provides an overview of various comparative legal frameworks for criminalizing the transmission of infectious diseases and their placement within different comparative legal models. The models considered are (i) personal injury-based, (ii) public injury-based, (iii) personal concrete endangerment-based, (iv) public concrete endangerment-based, and (v) public abstract endangerment-based models. While it is theoretically possible to develop a personal abstract endangerment-based model, comparative legal analysis shows that such incriminations do not appear in practice. In determining the appropriate comparative legal model for a particular incrimination, an analysis of the specific offense is necessary to identify the protected interest and the prohibited consequence. Many countries recognize multiple offenses related to the transmission of infectious diseases to ensure comprehensive criminal protection. Criminal law must provide protection for both personal interests and public interests, which can be achieved by criminalizing acts that endanger life, bodily integrity, health, and public health. Additionally, the master's thesis highlights deficiencies in the Slovenian criminal law regulation regarding the protection against infectious diseases.
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