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It is apparent to the most casual observer that a great divide separates the two systems of criminal procedure devised by Western man over the past eight centuries. When the comparatist turns his view from the Continent to the English speaking world, he encounters contrasts so striking that the great diversity existing within each legal culture pales in significance. Unfortunately, however, although it is an easy matter to enumerate countless striking differences between the two systems, it is far more difficult to investigate the extent to which these differences in detail can be traced to more fundamental differences in the way the two systems conceive of the nature of justice, order, and law itself.

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