Exclusionary Rules in Comparative Law

This book is a comparative study of the exclusion of illegally gathered evidence in the criminal trial , which includes 15 country studies, a chapter on the European Court of Human Rights, and a comparative synthetic conclusion.  No other book has un

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IUS GENTIUM COMPARATIVE PERSPECTIVES ON LAW AND JUSTICE

VOLUME 20

Series Editors Mortimer N.S. Sellers University of Baltimore James Maxeiner University of Baltimore

Board of Editors Myroslava Antonovych, Kyiv-Mohyla Academy Nadia de Araújo, Pontifical Catholic University of Rio de Janeiro Jasna Bakšic-Muftic, University of Sarajevo David L. Carey Miller, University of Aberdeen Loussia P. Musse Félix, University of Brasilia Emanuel Gross, University of Haifa James E. Hickey, Jr., Hofstra University Jan Klabbers, University of Helsinki Cláudia Lima Marques, Federal University of Rio Grande do Sul Aniceto Masferrer, Univeristy of Valencia Eric Millard, West Paris University Gabriël Moens, Murdoch University Raul C. Pangalangan, University of the Philippines Ricardo Leite Pinto, Lusíada University of Lisbon Mizanur Rahman, University of Dhaka Keita Sato, Chuo University Poonam Saxena, University of Delhi Gerry Simpson, London School of Economics Eduard Somers, University of Ghent Xinqiang Sun, Shandong University Tadeusz Tomaszewski, Warsaw University Jaap de Zwaan, Erasmus University Rotterdam For further volumes: http://www.springer.com/series/7888

Stephen C. Thaman Editor

Exclusionary Rules in Comparative Law

Editor Stephen C. Thaman School of Law Saint Louis University St. Louis, MO, USA

ISBN 978-94-007-5347-1 ISBN 978-94-007-5348-8 (eBook) DOI 10.1007/978-94-007-5348-8 Springer Dordrecht Heidelberg New York London Library of Congress Control Number: 2012954419 © Springer Science+Business Media Dordrecht 2013 This work is subject to copyright. All rights are reserved by the Publisher, whether the whole or part of the material is concerned, specifically the rights of translation, reprinting, reuse of illustrations, recitation, broadcasting, reproduction on microfilms or in any other physical way, and transmission or information storage and retrieval, electronic adaptation, computer software, or by similar or dissimilar methodology now known or hereafter developed. Exempted from this legal reservation are brief excerpts in connection with reviews or scholarly analysis or material supplied specifically for the purpose of being entered and executed on a computer system, for exclusive use by the purchaser of the work. Duplication of this publication or parts thereof is permitted only under the provisions of the Copyright Law of the Publisher’s location, in its current version, and permission for use must always be obtained from Springer. Permissions for use may be obtained through RightsLink at the Copyright Clearance Center. Violations are liable to prosecution under the respective Copyright Law. The use of general descriptive names, registered names, trademarks, service marks, etc. in this publication does not imply, even in the absence of a specific statement, that such names are exempt from the relevant protective laws and regulations and therefore free for general use. While the advice and information in this book are believed to be true and accurate at the date of publication, neither the authors nor th