نوع مقاله : علمی - ترویجی
1 استادیار گروه حقوق جزا و جرمشناسی، دانشکده علوم انسانی، دانشگاه دامغان، سمنان، ایران.
2 دانشجوی دکترای حقوق جزا و جرمشناسی، دانشکده ادبیات و علوم انسانی، دانشگاه ارومیه، آذربایجان غربی، ایران,
عنوان مقاله [English]
Persons assisting in the crime without any interference in the material property of the crime are considered accomplice in crime. Despite the adoption of a policy of accepting the criminality of the deputy in the crime, its rules are different in Iran, Scotland and the United States. The Islamic Penal Code has accepted a relative moratorium and milder punishment, in contrast to the offense of crime in Scotland and the United States; it varies according to the occurrence of the crime or its absence. Upon occurrence of crime, the approach of sentencing to criminal has the criminal offense of the deputy in relation to the incomplete crime of incitement or collusion in the the crime of dominate. Various approaches have been adopted on the quality of the material element. For example, leaving the verb with a legal obligation to prevent crime only in Scotland and the United States and assistance after committing a crime is considered only in the United States as a vicegerent in the crime. In Scotland and the United States, despite the common criminal downgrade Mens rea carelessness lessen. The present paper, by analyzing the differences between approaches, descriptively analyzes with a study-library, seeks to differentiate and in crime in the studied countries.