Participaţia penală în dreptul comparat
Criminal Participation in Comparative Law

Summary/Abstract: In the comparative law, in the case of the co-operation of several persons for the commission of a crime, several systems are established, where other categories of participants appear next to the author. A first category of legislation recognizes only the existence of the author and the accomplice, others provide for the participation in the form of the author, the accomplice and the instigator, and the last category stipulates four categories of participants. For all of this, it is important to distinguish between categories and to analyze which are the specific papers for each one, for their correct classification. It is also important to note that, while in a country's law, complicity has a definition, it may have the meaning of instigation in the law of another.

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