Reference
Comparisons
How JusticeCenterID compares institutional arrangements between countries, and the rules a comparison must satisfy before it is published.
Published comparisons
Each one is checked against the rules below before it is published, and each says on its face what it does not establish.
- Who polices what
- Thirty systems against five structural questions, with every answer sourced and every unresearched cell left visibly empty. No score, no ranking, and no country compared for quality.
- Who prosecutes, and where they sit
- Thirty-two systems against five structural questions about the prosecution service, with every answer restating a sourced claim from that country’s prosecution page. No independence score, no ranking, and the most contested questions left visibly unanswered.
- Who watches the justice system, and how far they reach
- Thirty-two systems against four structural questions about oversight, including how far each arrangement actually reaches. Every filled answer restates a sourced claim from that country’s oversight page, and the empty cells distinguish what was never researched from what was researched and not found.
- Who guards the border
- Seven structural questions about who guards a border, asked of every system whose border module is published. A body corporate, an agency established in a department, a force within a department, a federal police force, a component of the armed forces, a formation constituted by its own act and an authority of the central administration — different things wearing one English phrase, with the immigration function in a different place in each.
This page previously said that no comparison had been published, and set out the standard one would have to meet; that standard is the list below, and it is what every comparison above was built against.
What a comparison must satisfy
Comparison is the most error-prone thing this platform will do. These are the rules that make it defensible.
- Compare functions, not names
- Start from the function — "who decides whether a charge is brought" — and then identify which body performs it in each system. Starting from institution names imports one system’s categories into another.
- Equivalence is itself a claim
- Saying two institutions correspond requires a source that makes the comparison. We do not assert equivalence because the roles look similar.
- State what is not comparable
- Statistics collected under different definitions are not comparable, and saying so is more useful than a heavily caveated table. Where the underlying definitions differ, we say that instead of presenting numbers side by side.
- Sources on both sides
- Each side of a comparison needs its own primary or official sources. A well-sourced account of one country plus a general impression of another is not a comparison.
- No ranking
- We do not score or rank countries or institutions. Ranking requires a measurement methodology, and any ranking is only as defensible as the methodology behind it. Where an authoritative body has published an assessment, we would cite and attribute it rather than produce our own.
- No implicit default
- No country is used as the baseline against which others deviate. A comparison that treats one arrangement as normal and the other as a variation has already made an argument.
Comparisons still worth making
Genuine institutional questions, listed so the direction is visible. None of these is published yet.
- Who directs a criminal investigation: police, prosecutor, or investigating judge.
- Where the prosecution service sits in relation to the executive.
- Who decides the facts at trial: professional judges, juries, or mixed panels.
- How police complaints are investigated, and by whom.
- How places of detention are inspected, and who may enter unannounced.
- Whether courts may set aside primary legislation, and through which court.
Alongside those, every guide on this site contains a required section on how the topic varies between jurisdictions — see, for example, what a prosecutor does.