Constant reference has been made, especially in the early chapters, to the practices and theories of jurists and judicial systems of sundry lands, wherever appropriate, since the comparative element is one of the essential characteristics of this work. Newly emergent states of the world adapt their needs to the legal and social patterns of others. The United States has both profited from and contributed to other systems. Basically English in origin and design, features of its judicial system and process nevertheless both resemble, and differ drastically from, that of others. The legal systems of England and Wales, France, and the Soviet Union are most useful in an analysis in this connection. In the following pages a relatively brief view of the courts of these three countries will be presented, with a diagram for each system.
It is in fact incorrect to think of the courts of " Great Britain" or of the "United Kingdom" as a unified judicial system. For there exist actually three difterent systems in the United Kingdom of Great Britain and Northern Ireland: one for England and Wales; one for Scotland; and one for Northern Ireland. Only at the ultimate appellate level of the House of Lords is it possible to speak with accuracy of a unified system for the United Kingdom; because that body in its judicial role represents the final court of appeals -- in those very few cases that manage to reach it -- from the judgments of the highest courts of Scotland and Northern Ireland as well as from those of England and Wales. The following description is of the judicial system of England and Wales -- for