Just as nations differ in the crime laws that are set, the study of comparative law shows that they also differ in the processes used to enforce these laws. Importantly, for example, nations differ in their use of juries. In Great Britain, the United States, Canada, and Australia, the accused has a right to be tried by a jury composed of fellow citizens. In France, Russia, and Brazil, that right is reserved for only the most serious crimes. In India and throughout Asia, all defendants are tried by professional judges, not juries. Yet China recently introduced mixed panels consisting of one judge and two lay jurors. Beginning in 2009, Japan also started to use a quasi-jury system, called saiban-in, in which three law-trained judges and six lay citizens chosen by lot- tery come together to render verdicts and sentencing decisions by a majority vote. Ever since juries were abolished in Japan during World War II, all Japanese defendants have been tried by three-judge panels; almost all have been con- victed, typically after confessing to save face and minimize embarrassment to the family.
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