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Sir William Macpherson did, however, suggest that consideration be given to ending the double jeopardy rule to permit prosecution after acquittal where fresh and viable evidence is presented.
"Thorough legal research by myself and my staff led to the conclusion that Georgia law presently does not permit prosecution of Ms. Jones for any alleged acts relating to the end of her pregnancy," Edwards said.
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Under the "intent to reward" prong, the majority of circuits permit prosecutions for mere gratuities, but some do not.
Section 134 (sub-section 1) of the Criminal Justice Act permits prosecution of foreign war criminals in the UK under so-called universal jurisdiction.
He is the first person to be tried under a 1991 war crimes act that permits prosecution for crimes committed outside Britain.
Judge Garzón had already established his reputation as an international defender of human rights by making extensive use of Spain's doctrine of universal jurisdiction, which permits prosecution within Spain of crimes committed outside the country.
Lawyers saw the case as breaking new legal ground: Mr. Nzapali is the first person to be convicted in a Dutch court under a new law permitting prosecution of human rights crimes even though they happened in another country.
In U.S. law, for example, Congress has passed statutes permitting prosecutions under all of the jurisdictional bases listed above.
The ruling is also expected to call into question a law permitting prosecutions for terrorist crimes for which the statute of limitations has expired.
This is not the case on railways, however, where bylaws permit criminal prosecution (with a six-month statute of limitation).
The Justice Department, however, took a much more aggressive approach in this case by charging Ms. Gonzalez with violating other federal statutes that permit the prosecution of any defendant, including foreign officials.
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