Lawyers at Vey & Associés exchange views with the teams at Schillings on the structural differences between the French and English approaches to criminal procedure and complex disputes.

These expert discussions highlighted a point that while both systems pursue justice, the procedural frameworks underlying civil law and common law traditions differ profoundly.

Her are some key distinctions:

▪️ Role of the judge: active in the French system, more referee-like in the English system
▪️ Evidence gathering: led by the investigating magistrate in France, party-driven in England
▪️ Trial format: predominance of the written dossier versus oral advocacy and cross-examination
▪️ Victims : the unique French mechanism allowing victims to join criminal proceedings directly

These differences are not only theoretical — they directly shape defence strategies, cross-border investigations, and coordination between counsel in high-stakes matters.

This work between practitioners from different legal traditions is essential in today’s increasingly international disputes environment.

Many thanks to the Schillings teams for the quality of these discussions.