The aim of the study is to comparatively analyse the practice of implementing probation systems in different countries in order to identify best practices and opportunities for their adaptation in other jurisdictions. For this purpose, the legislation that regulates the institution of probation in Kyrgyzstan, Kazakhstan, Turkey, as well as in some countries of the European Union, namely: UK, Netherlands, Sweden, France, and Germany. According to the study, the probation institution is an essential component of the criminal justice system, as it allows for the supervision of convicts while they are still at liberty. The effectiveness of this institution is often questioned as it requires significant funding, qualified staff and supervision. The introduction and effective operation of the probation institution is hampered by funding problems, a shortage of skilled professionals, and the difficulty of building trusting relationships with inmates. Individual re-socialisation programmes for inmates, constant monitoring of their implementation, social and psychological support for inmates and their families, and participation in the rehabilitation of inmates through social and preventive work are some distinctive characteristics of the practice of implementing probation institutions. The way in which probation institutions are implemented varies from country to country, from legislation to legislation, and from social structure to social structure. But in most countries, this institution focuses on the rehabilitation of convicted persons and reduction of recidivism, which is a goal common to all probation systems, which is in line with generally recognized principles of international law, criminal procedure. In order to exchange information and plan activities for the implementation of re-socialisation programmes, the practice also involves communication with other institutions and experts in the criminal justice system.
Kuldysheva et al. (Thu,) studied this question.