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Paper in which the author aims to compare the reasoning of and approaches to the exclusion of certain evidence in criminal litigation in England, in the United States and in Japan, with reference in particular to the potential impact of the Human Rights Acts 1998 on the increased possibility that the defence challenge the admissibility of prosecution evidence alleging breach of the European Convention on Human Rights. Article by Ryo Ogiso (Associate Professor, Faculty of Law, Komazawa University, Tokyo, Japan. Published in Amicus Curiae - Journal of the Institute of Advanced Legal Studies and its Society for Advanced Legal Studies. The Journal is produced by the Society for Advanced Legal Studies at the Institute of Advanced Legal Studies, University of London.

The Exclusionary Rule in Criminal Procedure: a comparative study of the English, American, and Japanese approaches