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The first part of this chapter examines how commentators in both adversarial and inquisitorial systems have looked to the other system as a means to prevent wrongful convictions. Those in adversarial systems have been attracted to inquisitorial commitments to truth-finding, aversion to plea bargaining and fact-based appellate revisions. Those in inquisitorial systems have looked to the role of the defence counsel in calling and cross-examining witnesses and public and transparent fact-finding. The second part illustrates some differences among inquisitorial systems by contrasting the correction of wrongful convictions in Sweden and Norway and the different use of guilty pleas in China and Taiwan. The next part examines how German, Italian, French, Chilean and Japanese systems remedy wrongful convictions, including through fact-based revision procedures. Finally, trends in the use of guilty pleas and summary procedures in those countries are examined. Although it is diminishing, inquisitorial systems still have an advantage over adversarial systems because of their caution in relying on guilty pleas and summary procedures for serious offences.
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