COMPARATIVE
POLICE SYSTEM
COMPARATIVE
Denotes the degree or
grade by which a person,
thing, or other entity has a
property or quality greater
or less in extent than that of
another.
POLICE
A police service is a public force
empowered to enforce the law and to ensure
public and social order through the
legitimized use of force.
“Police are the public and the public are the
police”- Sir Robert Peel
SYSTEM
A combination of related elements that is
functioning as a whole in order to achieve a
single goal or objective.
COMPARATIVE POLICE SYSTEM
Process of outlining the similarities and
differences of one police system to
another in order to discover insights in
the field of international policing.
It is the science and art of investigating
and comparing the police system of
nations. It covers the study of police
organizations, trainings and methods of
COMPARATIVE CRIMINAL JUSTICE
It is subfield of the study of Criminal Justice that
compares justice systems worldwide. Such study
can take a descriptive, historical, or political
approach.
It studies the similarities and differences in
structure, goals, punishment and emphasis on
rights as well as the history and political stature of
different systems.
THREE BASIC Functions of Criminal Justice System
1.Policing
2.Adjudication
3.Correction
International Criminal Justice
It involves the study and description of one
country’s law, criminal procedure, or justice
(Erika Fairchild).
Comparative criminal justice system
attempts to build on the knowledge of
criminal justice in one country by
investigating and evaluating, in terms of
another country, culture, or institution.
MODEL SYSTEM
is used to describe the countries being used
as topics of discussion. These countries are
chosen not because they are greater than
others but because they are the focus of
comparison being studied.
Why Compare?
Crime has become a global phenomenon.
Transnational crimes cross borders and the
need for bilateral and international
cooperation become imperative.
2 METHODS OF COMPARATIVE
POLICE SYSTEM RESEARCH
1. SAFARI METHOD- a researcher
visits another country
2. COLLABORATIVE METHOD-
the researcher communicates
with a foreign researcher
THEORIES IN POLICING SYSTEM
HOMERULE THEORY CONTINENTAL THEORY
Policemen are servants of the Policemen are servant of higher
community authority.
Effectiveness of policemen depends They just follow the wishes of top
on the express wishes of the people. official of the government
OLD POLICING MODERN SYSTEM
The yardstick of the efficiency of The yardstick of police efficiency is
the police is determined by the the absence or lesser occurrence of
number of arrest. crimes.
Punishment is the sole instrument Police omnipresence is considered
of crime control. as the tool or instrument in crime
prevention.
THEORIES OF
COMPARATIVE POLICING
1. INSTITUTIONAL THEORY
Posits that police structures and practices
are shaped by formal institutions, laws, and
governance frameworks within a country. It
emphasizes how political and legal systems
influence police behavior
2. CULTURAL THEORY
Cultural theory focuses on how societal
values, norms, and beliefs influence policing
styles and expectations. It posits that
policing reflects the culture it operates
within.
3. FUNCTIONALIST THEORY
It views police institutions as necessary
components that serve vital functions in
maintaining social order. It compares how
various societies fulfill the policing function.
4. POLITICAL ECONOMY THEORY
This theory examines how economic
systems and class relations influence
policing. It suggests that policing is often
used to protect the interest of dominant
economic groups.
5. GLOBALIZATION TEORY
Explores how global trends and institutions
affect national policing practices, including
the diffusion of policing models and
international cooperation.
6. POSTCOLONIAL THEORY
This theory critiques the legacy of
colonialism in shaping contemporary
policing in former colonies. It emphasizes
how colonial policing models persist or are
reconfigured.
THEORIES OF COMPARATIVE
CRIMINOLOGY
1. ALERTNESS TO CRIME THEORY
postulated that as a nation
develops, people’s alertness to
crime is heightened. They report
more crime to police and
demand the police to become
more effective in solving crime
problems
2. ECONOMIC OR MIGRATION THEORY
Asserts that crime
everywhere is the result or
unrestrained migration
and overpopulation in
urban areas such as
ghettos and slums.
3. OPPORTUNITY THEORY
is that along with higher standards
of living, victims become more
careless of their belongings, and
opportunities for committing crime
multiply.
4. DEMOGRAPHY THEORY
- Is based on the event when a greater
number of children are being born. As
these baby booms grow up, delinquent
subcultures develop out of the
adolescent identity crisis.
5. DEPRIVATION THEORY
holds the progress comes along with
rising expectations. People at the
bottom develop unrealistic expectations
while people at the top don’t see
themselves rising fast enough.
6. MODERNIZATION THEORY
- sees the problem as society
becoming too complex.
7. THEORY OF ANOMIE AND
SYNOMIE
( the latter being a term
referring to social cohesion on
values), suggests that
progressive lifestyles and norms
results in the disintegration of
older norms that once held
people together (anomie).
COMPARATIVE POLICING VS. COMPARATIVE
CRIMINOLOGY
COMPARATIVE POLICING is the study of
police systems, functions, and practices
across different countries or jurisdictions,
examining how police are organized, how
they operate, and how they interact with
communities and governments.
COMPARATIVE CRIMINOLOGY is the
study of crime and criminal justice systems
across different countries or cultures to
understand patterns, causes of crime, and
responses to it.
4 TYPES OF
CRIMINAL JUSTICE
LAW IN THE WORLD
1. COMMON LAW SYSTEMS
are also known as Anglo-American Justice, and
exist in most English-speaking countries of the
world, such as the US., England, Australia and
New Zealand. They are distinguished by a
strong adversarial system where lawyers
interpret and judges are bound precedent.
Common law system are distinctive in the
significance they attached to precedent (the
importance of previously decided cases). They
primarily rely upon oral systems of evidence in
which the public trial is a main focal point.
2. CIVIL LAW SYSTEM
are also known as Continental
Justice or Romano-Germanic
Justice, and practice throughout
most of the European Union as well
as elsewhere, in places such as
Sweden, Germany, France and
Japan. They are distinguished by a
strong inquisitorial system where
less right is granted to the accused,
and the written law is taken as
For example, a French maxim goes like
this “If a judge knows the answer, he
must not be prohibited from achieving it
by undue attention to regulations of
procedure of evidence”. By contrast, the
common law method is for a judge to at
least suspend belief until the event of a
trial is over. Legal scholarship is much
more sophisticated and elitist and civil
law system, as opposed to the more
democratic common law countries where
just anybody can get to the law school.
Romano-Germanic systems
are founded on the basis of
natural law, which is a respect
of tradition and custom. The
sovereigns or leaders of a civil
law system are considered
above the law, as opposed to
the common law notion that
nobody is above the law.
3. SOCIALIST SYSTEM
are also known as Marxist-Lenninist
Justice, and exist in many places , such
as Africa and Asia, where there had
been a Communist revolution or the
remnants of one. They are
distinguished by procedures designed
to rehabilitate or retrain people into
fulfilling their responsibilities to the
state. It is the ultimate exorcession of
positive law, designed to move the state
It is also primarily characterized
by administrative law, where non-
legal officials make most of the
decisions. For example, in a
socialist state, neither judges nor
lawyers are allowed to make law.
Law is the same as policy, and an
Orthodox Marxist view is
eventually, the law will not be
necessary.
4. ISLAMIC SYSTEMS
are also known as Muslim or Arabic Justice,
and derived all their procedures and
practices from interpretation of the Koran.
Islamic system in general are characterized
by the absence of positive law (the use of
law to move societies forward toward some
progressive future) and are based more on
the concept of natural justice (crimes are
considered acts of injustice that conflict
with tradition). Religion plays an important
role in Islamic Systems.
COMPARATIVE COURT SYSTEM
Court Systems of the world are of two types:
1. ADVERSARIAL- where the
accused is innocent until proven
guilty.
The U.S adversarial system is
unique in the world. No other
nation, not even the U.K places as
much emphasis upon
determination of factual guilt in
2. INQUISITORIAL
where the accused is guilty until proven
innocent or mitigated, have more secret
procedures.
Outside the U.S, most trials are concerned
with legal guilt where everyone knows the
offender did it, and the purpose is to get
the offender to apologize, own up to their
responsibility, argue for mercy, or suggest
an appropriate sentence for themselves.
COMPARATIVE CORRECTIONAL SYSTEM
Correctional systems worldwide can be easily
distinguished by whether they support corporal
punishment (beatings) or not. Some so-called
“civilized” countries claim they are better than
U.S because they don’t perform death penalty
but actually practice such corporal punishments
as beatings and whippings. Nations that practice
corporal punishments do tend, however, to have
less of a correctional overcrowding problem.
Probation and parole, where they exist cross-
culturally, are applied to the countrie’s citizens,
and not for foriegners or immigrants.
COMPARATIVE JUVENILE JUSTICE SYSTEM
Juvenile Justice System vary
widely. Scotland has the toughest
system, regularly sentencing
juveniles to harsh boot camps with
a strict military regiment and
forced labor. Germany has a
juvenile justice system similar to
the U.S., where more emphasis is
upon education as punishment.
MODELS IN POLICING
Basic Goals of Policing
1. Enforce Laws
2. Preserve Peace
3. Prevent Crimes
4. Protect civil rights and liberties
5. Provide Services
Different Models of Policing
a. Crime Control Model
Based on the presumption that the repression of criminal
behavior is the most important aspect of police duty and
therefore should be given priority.
This approach has been rationalized in the past by the
assumption that inconvenience or harassment of innocent
people can be justified by the fact that police are fighting
the crime.
b. Due Process Model
- When due process is the primary object of policing, police
policy is that is far better than 100 guilty men escape
justice rather than one innocent person be convicted.
Classification based on legitimacy or legal
backing of police function
a.Policing by consent- policing works
on the principle of consent. This is
primarily applicable in parliamentary
democracy.
b.Policing by law- policing power is
vested on State by law.
Classification based on Command Structure
Centralized law enforcement- simply means one police force operating
in a country. The police force in a country has a centralized command.
Decentralized law enforcement- refers to a system where police
administrations and operations are independent from one state to another.
The police force in a country do not have a centralized command. It is
more applicable to countries with federal government.
Types of police in the world
1. Uniformed police - a law enforcement officer who wears a distinctive
uniform as part of their duty.
2. Detectives - Also known as criminal investigators, police detectives
investigate crimes including robberies, arson, homicides and property
crimes. As a police detective, you can specialize in one of these specific
types of crime.
3. Auxiliary - volunteers who support regular law enforcement by
performing tasks like crowd control, crime prevention, and traffic
control. They may also assist with first responder duties, reporting
hazardous conditions, and investigating animal complaints.
4. Special police - often refer to law enforcement officers who have
specific roles or jurisdictions within a larger police force or agency, or
who are granted law enforcement powers incidental to their primary
duties.
5. Military police - are the law enforcement branch of the armed
forces, responsible for maintaining order and enforcing regulations
within military communities and during military operations.
6. Religious police - in Saudi Arabia they call is as the “Mutaween”
which is specialize in enforcing the strict religious customs of Sharia
law.
7. Border police - also known as border patrol officers or border
guards, are law enforcement officials tasked with securing national
borders and preventing illegal activities like smuggling, trafficking,
and unauthorized entry.
8. Transport police - An example of transport police is the British
Transport Police (BTP), which is the national police force for the
railways in the UK. They are responsible for policing the rail network,
including stations, trains, and surrounding areas.
INNOVATIVE POLICING
Community Policing - It is the deployment of law enforcement
professionals to work in and around schools.
Broken Windows Theory - This theory says that the little things matter. It
comes from the concept: “If a window is broken and left unrepaired,
people walking by will conclude that no one cares and no one is in
charge”.
The “broken window” is a symbol of unaccountability. So, enforcing the
smallest laws could prevent the large ones from being broken.
Problem- oriented policing
An approach to policing which discrete pieces of police business
are subject to microscopic examination in hopes that what is freshly
learned about each problem will lead to a new more discovering a new
and more effective strategy for dealing with it.
Pulling levers policing - It consists of selecting a particular crime problem,
convening an inter-agency working group of law enforcement, prosecution,
other justice agency officials, local government, social service, and
community- based practitioners.
Pulling levers focused on deterrence strategies which are associated
with an overall statistically- significant, medium- sized crime
reduction effect.
Third party policing - It describes police efforts to persuade or coerce third
parties, such as landlords, parents, local governments, and other regulators to
take some responsibility for preventing crime or reducing crime problems.
In third party policing, the police create crime control guardians in
locations or situations where crime control guardianship was previously
absent.
For example, taxation laws regulate business practices and give taxation
agents the authority to compel businesses to adopt accounting methods
and procedures that reduce risks and likelihood of business fraud.
Hot spot policing - A popular policing strategy that addresses crime
by assigning limited police resources to areas where crimes are
more highly concentrated. It is also referred to as place- based
policing.
CompStat policing - The Computer Comparison Statistics
(CompStat) is a multifaceted system for managing police operations.
It is used in in many law enforcement agencies in the US and round
the world.
The CompStat is guided by four principles which are as follows:
1. Accurate and timely intelligence
2. Effective Tactics
3. Rapid Deployment
4. Relentless follow up and assessment
Evidence policing - This policing focused on evidence- based
practices. Definition of evidence- based practice as presented
by Dr. James Chip: “Rather than relying on conviction,
conjecture, or conventional wisdom, decision makers turn to
the best available evidence about what does and does not work
when evaluating options and making decisions in order to
identify and choose the optimal approach in policy,
management, and other applied settings.
