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The article (i) clarifies the origin, content and characteristics of the criminal procedural 1 model in the world, together with the contrast between the interrogation procedure model and the litigious procedural mode; (ii) clarifies the relationship between procedural models and court characteristics and characteristics of litigation procedures; (iii) states the need to study the comparison between the procedure of litigation at the criminal trial in the United States, Japan and Vietnam and provide in-depth comments, as well as draw assessments and conclusions about litigation procedures and related matters in relation to the used procedural system.
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Nguyen Ngoc Kien (2019) studied this question.
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