Nemzetközi elvárások a fiatalkorúak büntető igazságszolgáltatásával kapcsolatosan, különös tekintettel a büntetéskiszabásra

The specific nature of the juvenile justice system varies from country to country, with the diversity of approaches being explained by the economic, political, cultural and social differences between States. A typology, according to John A. Winterdyk (2015), classifies these systems into six models, by the purpose of the intervention, the perception of the behaviour of the juvenile subject to the proceedings, the main characteristics of the proceedings, the institution playing a key role in the proceedings, the task to be performed by the institution and the mission of the system. It is not possible to fit all countries into a single model, but they can be used to identify the main features of the juvenile justice system in each country. Since the 1980’s, a number of international documents have been produced on juvenile justice, partly with a view to replacing the repressive treatment system and to making the justice system more effective in preventing re-offending. To this end, the socalled responsibility model has been gradually introduced with the aim of making juvenile offenders responsible of their actions. The model has led to changes in juvenile justice systems across Europe, which are also significant in terms of sentencing. In my study, I will show how the international documents reflect the pervasive principle of juvenile sentencing and how the different conventions and recommendations give substance to the category of 'education'. I will examine and compare the international aspects with the domestic legislation on the issue of youth sentencing. Finally, I will compare the international standards for juvenile sentencing and the domestic provisions.