Does England have a model legal system? The question may prompt mirth in London, but in Paris - where criminal justice is under heavy fire - it is posed with increasing frequency and gravity.
In France, conservatives and liberals, lawyers, politicians and human rights organisations have all been looking across the Channel, as they search for a swifter, cheaper and more equitable system.
Within the last month, the Justice Minister, Pierre Mehaignerie, has expressed interest in lay magistrates' courts, a concept unknown in France, while the influential Human Rights League has called on Paris to adopt the adversarial system. Calls for reform have been mounting in France for many years, but reached a peak last month with the trial in Nice of a Moroccan gardener, Omar Raddad.
Raddad was sentenced to 18 years in prison for murdering his employer, Ghislaine Marchal, a wealthy widow who was found stabbed to death in her house in June 1991. The case was always likely to capture public imagination, but was transformed into high drama by her final act.
On the walls of Mrs Marchal's basement, police found the statement "Omar killed me" written in her blood. At first it seemed a clear-cut case, but investigators found no other proof of Raddad's involvement in the crime, no forensic evidence, no motive and no witnesses.
At the trial last month, the defence suggested that Mrs Marchal could have been forced to write the statement incriminating Raddad, or that someone else could have written it.
Raddad's lawyer, Jacques Verges, was confident that his client would be acquitted on the grounds that there was doubt over his involvement, and did not attempt to hide his bitterness when the verdict went the other way.
"My client has been condemned because he is a Moroccan," Verges said. Other organisations offered support, with 18 eminent lawyers signing a statement saying it was "intolerable that the accused should be condemned when doubt existed". The French Association of Judges also criticised the verdict, saying that the prosecution had been "unable to prove its case".
Yet Raddad's trial has served not just to ignite public indignation (64 per cent of French people would like to see him re-tried, according to a recent poll), but also to push the French criminal justice system under the spotlight. In particular, the role of the president of the court is under scrutiny.
In France, presidents - effectively the chairmen of the three judges who sit in important cases - have the task of questioning witnesses and developing the arguments at the heart of a trial. They are supposed to remain neutral, yet according to observers, President Dijian left little doubt that he was convinced of Raddad's guilt.
Roland Kessous, president of the Commission on Police and Justice of the French Human Rights League, says: "I cannot comment specifically about Raddad's trial but I have been at many trials where it was clear that the president was convinced of the defendant's guilt. …