Appellate procedures regarding the most serious crimes under domestic law are, in general, conducted differently in common law and civil law systems. This article reviews the differences concerning the primary facets of such proceedings, namely prosecutorial rights of appeal, access to appellate review, the scope of appellate review, the admission of additional evidence, appellate decisionmaking powers, and the functions of appellate review. It then explains that these differences result from dissimilar decisionmaking processes, degrees of adherence to the search for the truth, and sources of law.
The Right to Appeal in Comparative Perspective,
19 J. App. Prac. & Process 187
Available at: https://lawrepository.ualr.edu/appellatepracticeprocess/vol19/iss2/4