The Criminal Justice System Of South Korea And Germany

Abstract

Criminal justice system forms an important part of any country’s judicial system. The system developed for controlling crime includes a group of methods and agencies created by the government for imposing penalties on persons who break the laws. A comparative analysis of the criminal justice systems of Germany and South Korea is carried out to understand the judicial systems, criminal laws, functions of police, juvenile judicial systems, and other areas of the criminal justice systems. The analysis of the crime data helped to understand how both countries differ in their effectiveness in controlling crime.

Introduction

The justice system for crime includes a group of methods and agencies created by the government for controlling crime as well as for imposing penalties on persons who break the laws. The way in which this justice system operates within every area relies on the jurisdiction that is in charge: state, city, county, tribal government, military installation, or federal government. Various jurisdictions include different agencies, laws, and methods of managing the justice system for crime. The main systems include the state criminal justice systems, which manage crimes committed within the state, and the federal criminal justice system, which manages crimes committed within the boundaries of federal property.

The three main elements which make up the justice system for crime are courts, law enforcement, and corrections. All these work together to prevent and punish deviant behavior.

• Law Enforcement is the most visible element. Police officers are usually the first persons who get calls about crimes committed. Police patrols then help to prevent crimes, investigate incidents of crime, and arrest people suspected of committing a crime. The culprits enter the court system after getting arrested.
• Court System: It constitutes judges, juries, and attorneys, along with ancillary staff. The innocence or guilt of the suspect is determined by the court. The suspected person, who is now a defendant, is given a chance to defend himself in court as the evidence is presented. He is then released or sent to jail if he has committed the crime. If he is found guilty, he receives a sentence depending on the criteria established by statutes and judges. The defendant is then sent to the correction system after he gets a sentence.
• Corrections System: It incorporates all kinds of punishment and sentencing. It includes probation and incarceration. A sentenced criminal becomes the responsibility of this system until he completes or serves his full sentence.

In this paper, the criminal justice systems of South Korea and Germany are reviewed.

Historical Background

Germany is one of the most prominent countries in Europe and has the largest economy. It is one of the wealthiest states in the world, having an average per capita income along with purchasing power of €16,200 in 2005 (France and Great Britain: €16,700). Germany has a middle-class society and a well-established welfare system, and poverty-linked social issues are relatively lower there. However, the latest economic performance of the state was not very dynamic, and the country became one of the slowest-expanding economies in the whole eurozone (Höfer, 2005).

Structural stiffness in the labor market of the state has made unemployment the biggest issue. The unemployment rate reached 12.5% by February 2005, which was the highest rate ever seen. The high rate of unemployment, along with the expanding population, has put a lot of stress on the welfare system and has lately cut down social services. Along with this, the reunification, integration, and modernization of the East German state have made its economic transition an expensive and lengthy process. Even though some progress was made in raising the living standards of the people of East Germany, the complicated process of integrating the former communist system and society is taking much longer than expected and still needs substantial financial transfers from west to east.

Criminal matters in the state largely depend on inquisitorial procedures, in contrast to the accusatory system in the UK. Thus, all prosecutions are performed by a separate prosecution service (Staatsanwaltschaft), which is independent of the police. It is the duty of the prosecution service to gather facts when people are suspected of a crime and to call the police to assist with the investigation. In fact, many cases work the other way around: police carry out the inquiry process, and the prosecutor may get involved as investigations are completed. The decision of the public prosecutor to indict the suspect or discontinue the proceedings is governed by law under the rule of mandatory prosecution. During criminal proceedings, the public prosecutor advises those who act for the prosecution. Germany has a separate juvenile justice system that emphasizes education instead of retribution for young people aged 14-18 and, under particular conditions, for young people aged 18-21 (Höfer, 2005).

The state of Korea was established around the 7th century in what is now modern North and South Korea. The Korean peninsula was declared a protectorate of Japan in 1905. It was annexed by Japan in 1910, and after the surrender of Japan in 1945 at the end of World War II, a Korean state emerged in the southern part of the peninsula. The communist state of the Democratic People’s Republic of Korea (DPRK) came into being in the northern section. Not long after, the US, as well as the UN, fought for the South during the Korean War from 1950 to 1953, a war intended to defend the southern part from communist forces. This ended in 1953 with the formation of the demilitarized zone at the 38th parallel (Yang, 1994).

This line of demarcation has divided the peninsula between the DPRK and the ROK since then. After the war, South Korea continued to achieve rapid economic progress compared with North Korea and is now considered a modern democratic country. Tensions between the two states are still very strong, but relations have been damaged because of attacks by the North on southern civilians and ships. As of 2026, the president of South Korea is Lee Jae Myung, while its capital is Seoul. With a few exceptions involving Chinese citizens, nearly 100% of the population is ethnically Korean, while the national language of the country is Korean. The religious demographics of the population are: 23.2% Buddhists, 49.3% have no religion, and 26.3% are Christian (Yang, 1994).

Criminal Law Description

The Strafgesetzbuch is linked with the old Penal Code system of the German Empire implemented in 1871, which is highly similar to the Penal Code system present in North Germany. This Penal Code system has two main sections:

General Section (“Allgemeiner Teil”): which manages general issues, for example:

• Attempts
• Essential defences
• Law-linked definitions
• Scope of the validity of law
• Ability to be pronounced guilty
• Enactment and provocation or accessoryship
• General means of punishment (like imprisonment and fines).
• Statutes of limitations

Special Section (“Besonderer Teil”): which includes a list of various criminal offenses as well as their definitions and sentences, for example:

• Crimes against life
• Crimes against the democratic rule of law.
• Crimes against public order
• Crimes of a sexual nature against individuals.
• Crimes against an individual’s wealth (like theft or robbery).

No Punishment Without Law

An individual who has violated the fundamental laws of a state or the rights of another individual will be punished. Criminal actions along with their legal consequences are governed only by the law of the state.

Only The State Is Authorized To Prosecute Criminal Offenses

Any sort of penalty through self-administered justice, non-state communities, or the head of a family is not allowed.

Public Attorneys (Staatsanwaltschaft), Police, And Courts

Witnesses and victims of criminal acts should contact the police by calling 110. The public attorney and police will then investigate whether there is any suspicion that a criminal act has occurred. Only the courts are allowed to convict a criminal defendant. Members of the justice system and police are not allowed to do this and must always act according to the law.

Every Individual Can Become A Witness And Should Speak The Truth

Any individual can be heard as a witness while a crime is being investigated. Only the wife, husband, or any close relative of the suspect can refuse to provide evidence. A witness should always speak the truth. False statements are themselves a crime, and a witness can be punished for them.

Some Of The Most Common Elements Of Crime

The use of physical violence is not allowed in Germany. This applies to family members, too, who should never physically punish anyone at home.

Sexual Self-Determination

This is a necessary element of legal protection. An individual who forces someone to perform a sexual act through threats or violence will be imprisoned for years. This applies to spouses, too. Sexual acts involving children under the age of 14 are not allowed and can be punished.

Drugs

Drugs are not allowed in Germany. An individual who sells, imports, possesses, or handles drugs will be punished.

Criminal Law In South Korea

Rules Of Evidence

The rules of evidence in Korea confer high probative value on suspect investigation records generated by the prosecutor, that is, protocols containing the statement of the suspect or any individual and prepared by the public prosecuting attorney or judicial officers. However, this document is technically hearsay in the US legal system and includes a record of confessions made without the help of legal advice. While either the prosecutor or the police constable can generate a record of a suspect investigation, one produced by the prosecutor is admissible if the suspect confirms the authenticity of the record during the preparatory stages or while the trial is underway. If the suspect refutes its authenticity, the evidence or record can still be admissible if there is a circumstantial guarantee of trustworthiness. However, a record or evidence made by the police is not admissible if the suspect later refutes its authenticity during the process (Ahn, 1997).

A suspect can confirm authenticity by signing a record upon completion when it is supposed to be confirmed. Another method of confirmation is through substantial acknowledgement in which the suspect confirms the record. A police-generated record needs to be substantially acknowledged.

Role Of Counsel

Presently, defendants’ lawyers perform a minimal role during the investigation procedure. Defence counsel is present during the process and can make objections only when the process is unjust. Counsel can make comments only after the investigations are approved (Carothers, 1998).

Jury Trial

Korea started experiments using a restricted form of the jury system in January 2008. The criminal law system consists of four chapters of general provisions, 42 chapters of individual provisions, addenda, and 372 clauses (Carothers, 1998).

General Provisions

Unit I. General Provisions

Chap. 01. Restriction on the Applicability of the Criminal Act (Carothers, 1998).

Chap. 02. Crime

• Section. 1. Commission of Mitigation and Crime or Exception of the Sentence.
• Section. 2. Criminal Attempts
• Section. 3. Involvement
• Section. 4. Frequent Crimes
• Section. 5. Simultaneous Crimes

Chap. 03. Punishment

• Section. 1. Forms and Harshness of Sentences
• Section. 2. Determination of Punishment
• Section. 3. Postponement of Imposition of Sentence
• Section. 4. Postponement of Implementation of Sentence
• Section. 5. Implementation of Sentence
• Section. 6. Parole
• Section. 7. Treatment for Implementation of a Ruling of Guilt.
• Section. 8. Extinction of Sentence
• Chap. 04. Term

Individual Crimes

• Unit II. Individual Provisions
• Chap. 01. Crime about Insurrection
• Chap. 02. Crimes about Foreign Aggression
• Chap. 03. Crimes about National Flag
• Chap. 04. Crimes about Foreign Affairs
• Chap. 05. Crimes against Public Peace
• Chap. 06. Crimes about Explosives
• Chap. 07. Crimes about the Responsibilities of Public Officials.
• Chap. 08. Crimes of Obstruction of the Performance of Official Duties.
• Chap. 09. Crimes about the Escape and Harboring of Criminals.
• Chap. 10. Crimes of Lying and Destruction of Evidence.
• Chap. 11. Crimes about False Accusation
• Chap. 12. Crimes against Deceased Persons
• Chap. 13. Crimes of Arson and Fire Caused by Negligence.
• Chap. 14. Crimes about Inundation or Water Utilization
• Chap. 15. Crimes about Traffic Obstruction
• Chap. 16. Crimes about Drinking Water
• Chap. 17. Crimes about Opium
• Chap. 18. Crimes about Currency
• Chap. 19. Crimes about Valued Securities and Revenue Stamps.
• Chap. 20. Crimes about Documents
• Chap. 21. Crimes about Seals
• Chap. 22. Crimes about Sexual Morals
• Chap. 23. Crimes about Gambling and Lotteries
• Chap. 24. Crimes of Homicide
• Chap. 25. Crimes about Infliction of Bodily Injury or Violence.
• Chap. 26. Crimes about Infliction of Bodily Injury or Death due to Negligence.
• Chap. 27. Crimes about Abortion
• Chap. 28. Crimes about Abandonment or Maltreatment
• Chap. 29. Crimes about False Arrest or Illegal Confinement.
• Chap. 30. Crimes about Intimidation
• Chap. 31. Crimes of Kidnapping
• Chap. 32. Crimes of Rape and Notorious Conduct
• Chap. 33. Crimes of Reputation
• Chap. 34. Crimes of Credit, Trade, and Auction
• Chap. 35. Crimes of Breach of Secrecy
• Chap. 36. Crimes of Intrusion into Human Habitation
• Chap. 37. Crimes of Hindering Another Person from Exercising His Right.
• Chap. 38. Crimes of Theft and Robbery
• Chap. 39. Crimes of Deception and Extortion
• Chap. 40. Crimes of Misappropriation and Breach of Trust.
• Chap. 41. Crimes involving Stolen Property
• Chap. 42. Crimes of Destruction and Damage

Distinctive Criminal Laws

After laws are enforced, crimes can become more serious or widespread. Also, in a few cases, a novel kind of threat occurs. Thus, special measures have been taken to combat such crimes. Nevertheless, for special crimes, the Criminal Act is considered the basic framework (Ahn, 1997).

The types of punishable actions for special crimes have increased, and the penalties for them have expanded in the same way, even leading to the death sentence. The following are a few examples of such special acts:

• An act concerning penalties for violent acts, intended to punish violent acts by a group or an individual.
• An act concerning additional punishment, etc., for specific acts, including bribery, hit-and-run accidents, child abduction, etc.
• The National Security Act, which punishes pro-communist propaganda or support for it.

Judicial System

The rules of Roman law form the basis of the judicial system of Germany and define a system of justice that differs fundamentally from the Anglo-Saxon system. In the US, courts depend on precedents from previous cases, while in Germany, courts rely on comprehensive legal codes. These codes delineate somewhat abstract legal values, and judges should decide particular cases according to those standards. The German judicial system includes three kinds of courts: ordinary courts, which deal with criminal and civil cases and are quite numerous; specialized courts, which deal with cases linked to administrative, social, fiscal, labour, and patent law; and constitutional courts, which deal with judicial review as well as constitutional interpretation. The federal constitutional court (Bundesverfassungsgericht) stands as the highest court and plays an important role through its interpretation of the Basic Law (Martinez, 2003).

The ordinary courts have four further tiers, each of great significance. The lowest tier includes a few thousand local courts (Amtsgerichte; sing., Amtsgericht), which deal with cases linked to minor offences or small civil issues. These courts also carry out routine legal operations, such as probation matters. The specialized courts have five distinct sections: social, fiscal, patent law, administrative, and labour. Similar to ordinary courts, they are managed hierarchically, with state court systems lying below federal courts. Sixteen judges make up the federal constitutional court, the highest and most important judicial body in Germany’s judicial system. They are selected to serve for 12 years under non-renewable terms and can be removed from office for abuse or by a motion given by the court itself. The Bundesrat and Bundestag each select half of the members of the court. Thus, partisan politics play a role, but compromise is built into the system because any decision of the court requires a two-thirds majority among the judges who participated in the case (Martinez, 2003).

Judicial System In South Korea

The Republic of Korea has a specialized judicial system. This judicial system comprises six high courts, an administrative court, and the Supreme Court of South Korea. Moreover, there are other courts with particular jurisdictions, such as family courts, as well as 13 regional courts. Regional courts contain sub-branches that are established similarly to municipal courts. One court is designated to deal with constitutional matters. According to the Constitution of Korea, significant judicial powers are vested in South Korean courts, as referenced in Articles 5 and 6. In spite of this, there was historically no proper jury system established for the court system of South Korea. Since February 2, 2008, some power has been given to juries. Questions related to fact and law are decided by judges. Furthermore, some authority is given to advisory panels, and they are used for civil and criminal cases (Im, 1987).

Public Courts:

Currently, there are 103 public courts in South Korea. Public or municipal courts deal with minor cases of daily life, such as disputes involving small claims that do not exceed twenty million won or cases in which punishment is announced for no more than 30 days or a fine of no more than two million won is charged against a criminal defendant (Im, 1987).

Regional Courts:

In South Korea, most criminal and civil cases are handled by 18 regional courts. Moreover, they deal with appellate panels that review appeal-related issues. Decisions in such cases are made either by a branch court jury or by a single regional court. An appellate panel is composed of three judges (Im, 1987). Normally, only one judge runs a case and gives the final decision. However, in some specific cases, there may be a panel of three judges that gives the final decision.

Subdivision Courts:

They are considered part of the regional courts. In South Korea, there are almost 40 subdivision courts. Although they perform many of the same functions as district courts, one limitation is that they lack appellate jurisdiction.

High Courts:

There are six high courts in South Korea. All of them deal with appellate cases. A panel of three judges is used in family or administrative court cases. Some civil cases are heard by one judge when the amount in controversy is more than 500 million won. Appeals in this court are heard by three judges. In South Korea, high courts are situated in Busan, Daejeon, Seoul, Gwangju, and Daegu. The Jeju High Court contains a special panel of the Gwangju High Court (Im, 1987).

Judges:

According to the Constitution of Korea, the Court Organization Act defines the qualifications of judges. Article 42 of this Act states that only those who have successfully passed the National Judicial Examination and completed a two-year training program at the Judicial Research and Training Institute (JRTI), or those who have a law degree, are qualified to become judges (Im, 1987).

The Chief Justice and then the Justices Council of Korea confirm the nomination of judges. This council consists of judges of the Supreme Court. The term of service for judges is ten years, and they can be selected again. The selection process and term of service described above do not apply to the Constitutional Court and Supreme Court of Korea. Both have their own procedures for nomination and terms of service. The Supreme Court and Constitutional Court of South Korea are the main regulatory judicial authorities in the country.

Juvenile Justice System

The youth justice system in Germany is regulated federally. The practice of youth justice has vacillated between punishment and rehabilitation in response to shifts in political power since the 1900s. After World War I, the state enacted legislation creating a system that incorporated both philosophies. In 1922, the Juvenile Welfare Act was passed, which addressed youth in need of care, while the Juvenile Justice system was established in 1923 to target youth delinquents (Albrecht, 2004).

Youth diversion has four different levels: diversion without intervention, diversion through non-judicial entities, diversion with interventions such as fines, community service, and apologies, and diversion requiring court proceedings. German law differentiates among age groups. “Children” under the age of 14 are not criminally culpable, while “juveniles” aged 14-17 fall under the responsibility of youth welfare departments. Young people aged 18 are considered adolescents and are criminally responsible, while people aged 21 or older are legal adults (Albrecht, 2004).

Germany revised the Juvenile Justice system in 1990. This system emphasized the least restrictive interventions for youth, introduced community sanctions, and increased diversionary options such as mediation and social training. Youth imprisonment has declined during the past 30 years; however, the proportion of youth placed under judicial control has increased since 1960 (Albrecht, 2004). One possible explanation for this expansion is that youth imprisonment is much cheaper (€100 to €200 each day) than placement of youth in residential treatment facilities (€250 each day).

In South Korea, everybody, including children or their guardians, has a different perception of the options available to them to fight violations of their human rights. The different options include complaints and petitions to organizations such as the National Human Rights Commission. The Constitution is very clear about people bringing their cases to a court of law. Every citizen who feels that their rights have been violated can challenge the violation in court. These rights are precisely stated and include the right to an attorney for anyone who is arrested and compensation by the state in cases of damage to property by a public official during the performance of official duties. Children are allowed to report to the police anything that they consider a violation of their rights, but a case involving serious legal issues can proceed only if they pursue it with a representative (Correction Bureau, 1993).

Crime Data

The following table compares the crime statistics of Germany and South Korea (Nation Master, 2017):

Prison System Description

The federal states of Germany manage all prison matters exclusively. The prison system is administered by the federal states. The procedure of imprisonment in penitentiaries has two purposes: the first is to ensure that when prisoners are released from prison, they will lead a social life without misconduct; the second is to protect people in society from those guilty of criminal acts. The main offices of prison services are located in the justice ministry of each state. Within the head offices, a prison service department looks after personnel matters, the employment of prisoners, and the rehabilitation of prisoners. It also regulates all organizational matters of prison services. Finances, construction, basic and advanced staff training, professional training, and prison-service legislation are all under the control of this department (Chammah, 2016).

Initially, imprisonment matters are handled by the public prosecutor’s office where a case is proceeding. Offenders imprisoned for the first time for fewer than three months are assigned among first-time prisoners (Erstvollzug). Reoffenders are placed in regular prisons (Regelvollzug). Those who receive long-term punishment are placed within high-security prisons (Langstrafenanstalt). Additional categories are made for adults, male prisoners, and those with health or mental issues (Chammah, 2016). A particular department manages prisons requiring therapy for inmates such as those who have committed sexual crimes. Prisoners are kept in groups of ten to fifteen. All of them are assigned to social activities. They are supported by psychiatrists, correction officers, and other social workers. In this way, they are given a valuable chance to correct themselves and eliminate social problems.

In 1976, a Prison Act was approved by federal regulation in Germany for the first time. It was specifically made for adults. The Federal Constitutional Court issued a decision in 2006. Because of that decision, some corrections had to be made regarding juveniles by the end of the following year. Five basic types of incarceration were used in Germany. They were Haft (safe keeping), Zuchthaus (custodial), Einschließung (jail), Gefängnis (prison), and Arbeitshaus (workhouse). Among them, Zuchthaus involved the most hard labor. Prisoners were involved in physical activities such as breaking hard rocks, and they had to work hard until the end of their sentence (Chammah, 2016).

Compared with the rest of the world, prisons in Korea are cleaner and safer. They are run professionally and with great care. It is said that Korean prisons are quieter and that the rate of rape there is almost equal to zero. Their prisons keep inmates engaged all the time by involving them in different activities and tasks. The normal weekday schedule is from 8 a.m. to 5 p.m., while inmates are kept in their respective cells during weekends or holidays so that correctional officers can have some time off.

Number And Type Of Prisons:

The total number of correctional facilities in Korea is 39. Of these 39, 26 are prisons, 1 is a women’s prison, 2 are juvenile prisons, 1 is an open prison, 5 are detention houses, 1 is a branch prison detention house, 2 are protection houses, and 1 is a branch prison (Correction Bureau, 1993).

Beds In Prisons:

There are no typical beds in the prisons of Korea.

Admissions Each Year:

The number of admissions in all correctional facilities in 1992 was 27,799 people (Correction Bureau, Various Years).

The Average Population Of Prisoners:

The average population in 1992 was 55,159. Of these 55,159 prisoners, 219 were under penal labour, and 31,169 were convicts. A survey conducted at the end of 1992 showed that 97.2% of the prisoners were male, and the remaining 2.8% were female. Among them, only 0.3% were foreigners.

Estimated Or Actual Number Of Inmates Imprisoned:

Detailed information about the actual percentages of prisoners imprisoned by annual admissions, type of crime committed, and other daily averages is not available. Yet, of these 34,499 inmates in 1992, the highest portion, i.e., 23.6%, was imprisoned for theft, the next highest portion, i.e., 17.1%, for robbery, and the third highest, i.e., 12.8%, were imprisoned under Special Laws concerning punishment for violent behavior (Correctional Bureau, 1993).

Functions Of The Police

The Federal Republic of Germany has given authority to sixteen states (Länder) to establish police organizations and maintain their police forces within their jurisdictions. They are also given the power to train police personnel and pass laws. The Basic Law establishes federal authority in the main areas of law enforcement. Germany has one federal police force, 16 state police forces, and three federal law-enforcement organizations (Tyler, 2007).

A range of law-enforcement tasks is accomplished by federal police, such as aviation security, railway policing, border protection, and maritime security. They may also serve in other foreign countries and handle organized crime and terrorism. The Aviation Security Act, Residence Act, Federal Police Act, and Germany’s Basic Law allocate all the above tasks. More than thirty-five thousand law-enforcement officers and five thousand other staff collectively make up the federal police, which is highly trained. It plays a vital role in maintaining security in Europe and the Federal Republic of Germany as well (Tyler, 2007).

Compared with Germany, the citizens of South Korea do not know how to handle their anger and usually target police officers, who become victims of the frustrations faced by ordinary people. They are often harassed by people for no reason. The police do not press charges against people because they feel unsafe and do not want to endanger their lives or jobs. Even when charges are pressed against ordinary citizens, which occurs in very few cases, only 50% of them are fined, and the rest get away with it. The fine for punching a police officer in South Korea is around $80, which is a very small amount and is one reason why people are casual about it, while no one increases the fine. The police are not liked by the people; although they are part of the government, they are oppressed by the public.

Conclusion

The justice system for crime includes a group of methods and agencies that are created by the government to control crime and impose penalties on persons who break the laws. The three main elements which make up the justice system for crime are courts, law enforcement, and corrections. The judicial system of Germany is based on the rules of Roman law. In Germany, courts rely heavily on comprehensive legal codes. These codes delineate somewhat abstract legal values, and judges decide particular cases according to those standards. The youth justice system in Germany is regulated federally. The practice of youth justice has vacillated between punishment and rehabilitation in response to shifts in political power. The federal states of Germany manage all prison matters exclusively. The prison system is administered by the federal states. The procedure of imprisonment in penitentiaries has two purposes, the first of which is to ensure that when prisoners are released from prison, they will lead a social life without misconduct.

The Republic of Korea has a specialized judicial system. This judicial system comprises six high courts, an administrative court, and the Supreme Court of South Korea. In South Korea, everybody, including children or their guardians, has a different perception of the options available to them to fight violations of their human rights. The different options include complaints and petitions to organizations such as the National Human Rights Commission. The Constitution is very clear about people bringing their cases to a court of law. Compared with the rest of the world, prisons in Korea are cleaner and safer. They are run professionally and with great care. It is said that Korean prisons are quieter and that the rate of rape there is almost equal to zero.

References

Ahn, K. W. (1997). The influence of American constitutionalism on South Korea. S. Ill. ULJ, 22, 71.

Albrecht, H.-J. (2004). Youth Justice in Germany. In M. Tonry and A. Doob (eds.), Youth Crime and Youth Justice. Comparative and Cross-National Perspectives, 443-493. Chicago: Chicago University Press.

Carothers, T. (1998). The rule of law revival. Foreign Aff., 77, 95.

Chammah, M. (2016). Germany has one of the most progressive prison systems for young people. Business Insider. Retrieved from https://www.businessinsider.com/germany-has-one-of-the-most-progressive-prison-systems-for-young-people-2016-10

Correction Bureau. (1993). Correctional Administration in Korea 1993. Ministry of Justice. Seoul, Korea.

Höfer, S. (2005). Crime and Justice in Germany: An analysis of recent trends and research. European Journal of Criminology.

Im, H. B. (1987). The rise of bureaucratic authoritarianism in South Korea. World Politics, 39(2), 231-257.

Martinez, J. S. (2003). Towards an international judicial system. Stanford Law Review, 429-529.

Nation Master. (2017).” All stats: Germany and South Korea compared”. Retrieved from https://www.nationmaster.com/country-info/compare/Germany/South-Korea

Reichel, P. L. (2002). Comparative criminal justice systems: A topical approach. Upper Saddle River, NJ: Prentice Hall.

Tyler, T. R. (Ed.). (2007). Legitimacy and Criminal Justice: An International Perspective. Russell Sage Foundation.

Yang, Sŏng-chʻŏl. (1994). The North and South Korean Political Systems: A Comparative Analysis. Boulder, Colo: Westview Press. ISBN 9780813388625.

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