Jacques Du Pasquier wrote:
>
> Robert J. Bradbury a écrit (22.12.2001/08:10) :
> > > "presumption of innocence"? (I hope this is the right term)
> >
> > The term is correct. However, I do not believe that it applies to
> > non-citizens of the U.S. In contrast, I believe in the French legal
> > system one is guilty until proven innocent (someone correct me if
> > this is wrong).
>
> I didn't follow the conversation but if intended generally in
> unlimited context then I correct you, this is of course wrong. I doubt
> that "presumption of culpability" explicitely exists in ANY legal
> system, as it is obviously unfair !
Actually, while Britain and most of the US has evolved under the common
law system, French law is a civil law system. In it, I beleive you do
not have a right against self incrimination, and while our system is
structured as an adversarial system of defense against prosecution, the
French system is structured where both sides put finding the truth as a
higher good than the rights of the defendant. For that reason, French
authorities have far more powers in interrogating suspects than US
police do.
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