Abstract
Across the spectrum of European legal systems a variety of models have been created to enhance the victim's chances of receiving compensation for injuries and losses suffered as a consequence of a criminal offence. In this article, three models are examined which allow the victim to claim compensation from the offender within the context of the criminal process. Each of these models has evolved in a distinct legal tradition and has specific merits and limitations. After weighing the respective strengths and weaknesses, and indicating how each model can be improved, the article concludes with a set of criteria that form a blue print of ‘best practice’.
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