The United States, United Kingdom, Russia and South Africa
How Are Their Police Systems Similar or Different?
Jackie Phillips
Criminology, Post University
CRJ402 Comparative Criminal Justice
CRJ402 Unit 7 Final Project: Comparative Criminal Justice
Dr. Lyndon Godsall
Congratulations! Your expertise in comparative criminal justice has gotten you promoted to the Head of Public Relations for the Police Department! This is an exciting time for you to put your knowledge to work and hit the ground running. You have just received an email from your boss with the details of your first project:
PART I: The Written Report Instructions:
An introduction expressing the value of understanding international justice systems.
This project is another reason why I absolutely adore the subjects of Criminology and Administration of Justice. Not only do I find the Police system in the United States fascinating because it directs how the country runs itself, but it is also a strong force that directs how other countries also run their government. Policing is needed for every country, state and city and how a country administers their Police force will direct the outcome of the country.
Choose three (3) countries covered in this course and complete a fundamental analysis and comparison of their criminal justice systems.
The countries I have chosen are South Africa, the United Kingdom and Russia. I have discovered that each of these countries are different countries and then their Police departments will also be significantly different from each other.
Briefly discuss the history of each country and how it has influenced its criminal justice system.
Country One: South Africa
“The Republic of South Africa is the southernmost country in the continent of Africa. It borders the Atlantic and Indian Oceans. Pretoria is the capital and Cape Town is the seat of Parliament, the legislative capital. The largest population of 80% is Black and the remaining population is Chinese, Indian, White and Multi-Racial. The languages spoken are Zulu, Xhosa, English, Dutch and Afrikaans.” (No Author Given, 2023)
“The Constitution of South Africa lays down that the South African Police Service has a responsibility to prevent, combat and investigate crime, maintain public order, protect and secure the inhabitants of the Republic and their property, uphold and enforce the law, create a safe and secure environment for all people in South Africa, prevent anything that may threaten the safety or security of any community, investigate any crimes that threaten the safety or security of any community, ensure criminals are brought to justice and participate in efforts to address the causes of crime.” (No Author Given, 2023)
Country Two: United Kingdom
“The United Kingdom of Great Britain and Northern Ireland is commonly called the UK or Britain. It is an island country off the coast of mainland Europe and surrounded by the Atlantic Ocean, Irish Sea, Celtic Sea and the English Channel with a population of over 68 million people. The Kingdom of Great Britain was formed in 1701 when the Kingdom of England and Kingdom of Scotland joined together.” (No Author Given, 2023)
“The law in England and Wales comprises common law and statute law. The organizational components of the criminal justice system include the government, criminal justice committees, police, courts, probation service, prison service, and Crown Prosecution Service. Procedures within the criminal justice system include detection and charging, remands, categories of offenses, magistrates' proceedings, trial by jury, and juvenile proceedings. Sentencing can take the form of imprisonment, suspended sentence, community penalty, fines, discharge, compensation, and capital punishment. There are also contingencies for appeals and early release.” (Barclay, G.C., 1993)
Country Three: Russia
“Russia has a very long and detailed history with a long list of rulers and many rulers trying to gain land and gain control of the surrounding lands. The earliest activity goes back to the year 862. After 1700, St. Petersburg became the capital of the new empire, the Russian Empire. The current Soviet Union was established after 1922 when four countries merged. In the 1980’s the Soviet Union was renamed the Russian Federation.” (No Author Given, 2023)
“Russia is the world’s largest country by area, and shares borders with countries in northern Asia and Europe. Identifying, investigating and preventing serious crime across Europe and Asia is a large part of the daily work carried out by INTERPOL’s National Central Bureau (NCB) in Moscow. The NCB’s global police cooperation activities are centered on Russia’s crime areas of priority concern; these include terrorism, organized crime – particularly drug and financial crime - and the international fugitive investigations these generate. Cybercrime is also an emerging crime area of concern.” (No Author Given, 2023)
Compare the roles of police officers in these countries
Russia:
“The Police of Russia are called Politsiya. All police forces are overseen by the Ministry of Internal Affairs, and currently the police are under wide reform. Until 2011 the police were called Militsiya. This change of name started at the Russian Revolution via a Communist political idea of "replacing the capitalist police by a people's militia"; but the name "militsiya" has persisted after the Communist system collapsed. Numerous cities in Russia have municipal police services and the Oblasts and Krais maintain regional police services. The Republics also have their own police forces. Russia's federal law enforcement agencies are the Federal Security Service and Federal Drug Control Service.
The standard Russian police baton is made of rubber. The normal service uniform is black with red piping and hat band. Fur hats and heavy greatcoats are worn in winter.” (No Author Given, 2023)
South Africa:
“The South African Police Service (SAPS) is the national police force of the Republic of South Africa. Its 1,154 police stations in South Africa are divided according to the provincial borders, and a Provincial Commissioner is appointed in each province. The nine Provincial Commissioners report directly to the National Commissioner. The head office is in the Wachthuis Building in Pretoria. The Constitution of South Africa lays down that the South African Police Service has a responsibility to prevent, combat and investigate crime, maintain public order, protect and secure the inhabitants of the Republic and their property, uphold and enforce the law, create a safe and secure environment for all people in South Africa, prevent anything that may threaten the safety or security of any community, investigate any crimes that threaten the safety or security of any community, ensure criminals are brought to justice and participate in efforts to address the causes of crime.” (No Author Given, 2023)
United Kingdom:
“Widely regarded as the home of the first modern police force, law enforcement in the United Kingdom is based on the long-standing philosophy of policing by consent. Policing and law enforcement are organized separately in each of the legal systems of the United Kingdom as a result of devolution of powers to Scotland, Northern Ireland and, to a lesser extent, London, England and Wales, have 43 local police forces (formerly known as constabularies), each of which covers a police area (a particular county, grouping of counties or metropolitan area). Since 2012, 41 of these forces have their own directly elected Police and Crime Commissioner, under the Police Reform and Social Responsibility. The two exceptions are in London, where the Metropolitan Police is accountable to the directly elected mayor via the Office for Policing and Crime, and the much smaller City of London Police that retains the Common Council of the City as its police authority.” (No Author Given, 2023)
Discuss critical issues that these countries are confronting.
United Kingdom:
“In September 2023, 61 percent of British people thought that the economy was one of the top three issues facing the country, compared with 43 percent who thought that health was one of the top three issues. The ongoing Cost of Living Crisis afflicting the UK, driven by rampant inflation is clearly one of the main concerns of Britons in 2023. Health is also a major issue for people in the UK. The share of people seeing health as a top three issue in January 2023 was the highest it has been since the Omicron wave of COVID-19 the previous winter. Staffing problems, along with increased demand for services have plunged the National Health Service (NHS) into a deep crisis, possibly the worst since its creation in the 1940s. Due to these ongoing problems, it is likely that the economy and health will remain the main issues for Britons throughout early 2023.” (Stipp, H., 2023)
South Africa:
“South Africa’s economic and social challenges are mounting, risking stagnation amid an unprecedented energy crisis, increasingly binding infrastructure and logistics bottlenecks, a less favorable external environment, and climate shocks. A recovery in the services sector supported job creation in 2022; however, employment remains below pre-pandemic levels and unemployment close to record highs, on the back of already high poverty and inequality. In addition, the economy remains exposed to external shocks and capital flow volatility, in the context of tighter global financial conditions, and volatile commodity prices related to Russia’s war in Ukraine. The elevated public debt significantly limits the fiscal space available to respond to economic and climate shocks and meet social and developmental needs. Long-standing rigidities in product and labor markets, and governance and corruption vulnerabilities also weigh on growth and employment prospects, threatening social cohesion.” (Graf, E., 2023)
Russia:
“While the constitution provides for freedom of expression, including for the press and other media, the government increasingly restricted this right. Federal, regional, and local authorities used procedural violations and restrictive or vague legislation to detain, harass, or prosecute persons who criticized the government or institutions it favored. The government exercised editorial control over media, creating a media landscape in which most citizens were exposed to predominantly government-approved narratives. Significant government pressure on independent media constrained coverage of numerous topics, especially Russia’s war against Ukraine; political prisoners; treatment of LGBTQI+ persons; problems involving the environment, elections, COVID-19, and corruption; and criticism of local or federal leadership, as well as secessionism or federalism. The government used direct ownership or ownership by large private companies with government links to control or influence major national media and regional media outlets, especially television. Censorship and self-censorship in television and print media and on the internet was widespread, particularly regarding points of view critical of the government or its policies. (No Author Given, 2022)
Share your thoughts on how the systems of these countries compare to the criminal
justice systems of the United States.
United States and United Kingdom:
“Differences in Policing Practices & Structures”
US | England & Wales |
Majority of officers carry guns on a routine basis | Few officers carry guns on a routine basis (though there are specific armed units) |
More ‘militarised’ approach to policing | More ‘community’ policing and policing ‘by the consent of the public’ |
Very decentralised police forces: 18,000+ police forces with varying practices and codes of conduct | Very centralised police forces: 43 Police Forces across England and Wales with national oversight and standardised codes of conduct |
Amount of training varies across forces | Considerable training required to become a police officer |
Amount of education required to become a police officer varies across forces | Educational requirements are standardised and follow specific guidelines for entry into the profession |
No national or federal oversight of police forces or police conduct | National and governmental inspection and oversight of police forces and police conduct |
(Belkin, L., 2021)
United States and Russia:
“The United States of America, formerly a mesh of European colonies, was founded through the execution of its constitution in 1789. After declaring independence in 1776, The Russian Federation., formerly known as the Russian Soviet Federal Federated Socialist Republic, or the Soviet Union for short, was founded through the execution of its constitution in 1993, after the fall of the. Soviet Union in 1991. The two nations were once rival superpowers, both with the abilities to have significant influence on events and interests on worldwide scale until the fall of the Soviet Union and its restructuring as the Russian Federation. While the United States of America has remained a Federal Republic with strong democratic tradition, the transition from the Soviet Union to the Russian Federation saw the nation's government transitioned from a socialist Republic to a federation. In both nations, the purposes of the criminal justice system are to deter, investigate and manage the influences of crimes against society and the states, and both nations can trace the histories of their legal systems to concepts founded in the Roman Empire of the Millennium past.” (Liebbe, J., 2021)
United States and South Africa:
“Along with many national historical similarities there appears to be similarities in the approaches these two governments have taken to remedy criminal justice issues that arise.
Political interference, lack of cooperation, poor communication skills, interagency discord and a lack of unified direction seem to plague both criminal justice systems. As a result, both criminal justice systems appear to be fragmented and in a constant state of flux.
One solution that attempts to remedy the mistrust developed by individual citizens and their communities as a result of the fragmentation of their criminal justice system is community policing. Both nations are embarking on a concept that was proposed by Sir Robert Peel in 1829 when he espoused the ideal of "Police, at all times, should maintain a relationship with the public that gives reality to the historic tradition that the police are the public and the public are the police.
The fragmentation which causes many of the dilemmas faced by the criminal justice system appears to be a necessary element of any system that wishes to be able to grow and change with time. As we embark on the 21st century, globalization will become a factor in every surviving national government. South Africa and the United / States appear to be positioning themselves to be active participants in this process.” (Ciller, C.H., Paitakes, J.M., 2002)
A conclusion that expresses your final thoughts on what you have discussed.
One of the biggest differences between the four countries is the recent history of each country in the past 50 to 100 years. The big internal changes in South Africa and Russia have caused significant changes in the policing systems because the countries themselves have gone through a lot of changes, which affects the rest of the country. In comparison, the United States and the United Kingdom have changed little in how their countries are governed and run, so that would cause little dramatic changes to the basic form of the police departments.
The United States and United Kingdom have had to face the changes of these countries and other countries, while inside their own countries, there has been little change. These facts have helped the US and UK be of assistance to other countries when they have asked, or the need has arisen to lend assistance.
References
Barclay, G.C., 1993, US DOJ Office of Justice, “Criminal Justice System in England and Wales, Second Edition,” https://www.ojp.gov/ncjrs/virtual-library/abstracts/criminal-justice-system-england-and-wales-second-edition
Belkin, L., 2021, Open University,“Differences and Similarities: Policing in the US and the UK,” https://www.open.edu/openlearn/education-development/race-and-ethnicity-hub/differences-and-similarities-policing-the-us-and-the-uk
Ciller, C.H., Paitakes, J.M., 2002, “A Comparative Analysis of Criminal Justice Processes in South Africa and the United States,” https://uir.unisa.ac.za/bitstream/handle/10500/864/thesis_boll_wc.pdf;sequence=3
Graf, E., 2023, International Monetary Fund, “South Africa: Staff Concluding Statement of the 2023 Article IV Mission,” https://www.imf.org/en/News/Articles/2023/03/21/mcs032223-south-africa-2023-article-iv-mission#:~:text=South%20Africa's%20economic%20and%20social,external%20environment%2C%20and%20climate%20shocks
Liebbe, J., 2021, The Aequitas Group, “A Comparative Analysis of the Criminal Justice Systems of the United States of America and the Russian Federation,” https://www.aequitasgroup.org/research/2011/03/comparative-analysis-usa-russia/
No Author Given, 2023, Wikipedia, “South Africa,” paragraphs 1 and 2, https://en.wikipedia.org/wiki/South_Africa
No Author Given, 2023, Wikipedia, “South African Police,” https://en.wikipedia.org/wiki/South_African_Police_Service
No Author Given, 2023, Wikipedia, “United Kingdom,” paragraphs 1 and 2, https://en.wikipedia.org/wiki/United_Kingdom#:~:text=The%20Treaty%20of%20Union%20between,of%20Great%20Britain%20and%20Ireland
No Author Given, 2023, Wikipedia, “History of Russia,” paragraphs 1 and 2, https://en.wikipedia.org/wiki/History_of_Russia
No Author Given, 2023, Interpol, “Tackling Eurasian organized crime,” https://www.interpol.int/en/Who-we-are/Member-countries/Europe/RUSSIA
No Author Given, 2023, Wikipedia, “Law Enforcement in Russia,” https://en.wikipedia.org/wiki/Law_enforcement_in_Russia
No Author Given, 2023, Wikipedia, “South Afrikan Police Services,” https://en.wikipedia.org/wiki/South_African_Police_Service
No Author Given, 2023, Wikipedia, “Law Enforcement in the United Kingdom,” https://en.wikipedia.org/wiki/Law_enforcement_in_the_United_Kingdom
No Author Given, 2022, US Department of State, “2022 Country Reports on Human Rights Practices: Russia,” https://www.state.gov/reports/2022-country-reports-on-human-rights-practices/russia/#:~:text=Significant%20government%20pressure%20on%20independent,federal%20leadership%2C%20as%20well%20as
Stipp, H., 2023, Statista, “Which of the following do you think are the most important issues facing the country at this time?” https://www.statista.com/statistics/886366/issues-facing-britain
