Comparative Analysis: Juvenile Justice Systems in Different Nations

This essay provides a comparative analysis of juvenile justice systems in Japan, Germany, and the United States. It highlights the differences in how these countries address juvenile delinquency, including the legal frameworks, sentencing guidelines, and the overall approach to juvenile offenders. The essay explains that Japan's system focuses on rehabilitation, while Germany prioritizes education and a more lenient approach. In contrast, the United States' system often mirrors adult criminal justice, applying constitutional rights to juveniles, which is not the case in the other two countries. The essay points out that the U.S. system often leans towards punitive measures, potentially contributing to higher crime rates, contrasting with the rehabilitative and educational approaches of Japan and Germany. The analysis includes references to the different legal codes and practices in each country and the key differences in their approaches to juvenile crime.

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Juvenile Crime
Juvenile delinquents are subjected to the consequences of breaking the law through
considerate ways rather than being charged with crime as in the case of adults. Different
countries have various ways of dealing with juvenile crime. This essay explains how Japan
and Germany deals with juvenile delinquency and how their approach differs from the system
employed by the United States.
The current Japanese juvenile law stipulates that citizens under the age of twenty are
juveniles and the system advocates for protective dispositions aimed at rehabilitation of the
juvenile offenders (interdyk, 2017). The penal code denies the ability of minors under the age
of fourteen to commit crime. Measures like placing a minor offender under probationary
supervision, committing a juvenile to child education and home training as provided by the
Child Welfare Law are used as correctional measures. There is a resort to juvenile
imprisonment with prescriptions of maximum and minimum periods in extreme offences.
Germany on the other hand consider juveniles to be citizens of below the age of
eighteen (Dunkel, 2017). The State Law though considers young adults too between the ages
of eighteen and twenty-one to be juveniles. The German system focuses more on education
instead of punishing the offenders. Their current system has a reduced custodial sanction of
six months, and a maximum of five to ten years. Juvenile offenders in this country are
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sentenced in the Juvenile court in cases of extreme offences according to sanctions of the
juvenile justice act. The sentences however, apply leniency and rationality in punishment
styles.
The Juvenile Justice system of the United States is different in ways like processing
juveniles as mature citizens (Wilson et al, 2017). The adult constitutional rights in the
American criminal justice are as well applied to juvenile offenders, which is not the case in
both the Germany and Japan. The newly established American Juvenile criminal systems
focus on punitive justice rather than a developmental progress of the juvenile offenders.
These harsh measures however are attributed to an increase in crime rates in the United
States.
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Works Cited
Dünkel, Frieder. “Juvenile Justice in Germany: Between Welfare and Justice.” International
Handbook of Juvenile Justice, 2017, pp. 225–262, 10.1007/978-0-387-09478-6_9.
Accessed 18 Apr. 2021.
Wilson, David, et al. Effectiveness of Restorative Justice Principles in Juvenile Justice: A
Meta- Analysis. , 2017.
Winterdyk, John A. Juvenile Justice: International Perspectives, Models and Trends. Google
Books, CRC Press, 14 Oct. 2018, books.google.com/books?. Accessed 18 Apr. 2021.
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