International Models of Juvenile Justice: A Comparative Legal Study and Pathways for Legislative Reform in Uzbekistan

Abstract

This article offers a comparative legal examination of the institutional and legislative practices developed in the United States, Germany, Norway, Iceland, Japan, the Russian Federation, and the Republic of Kazakhstan for combating and preventing juvenile offending. The purpose of the study is to identify the shared principles and distinguishing features of the juvenile justice frameworks that have emerged across different legal traditions, and to substantiate elements that could be incorporated into the legislation and law-enforcement practice of the Republic of Uzbekistan. The findings indicate that, despite institutional variation, every successful model reflects a common trajectory: a move away from punitive sanctions toward education and social rehabilitation, the development of specialized institutions, and the mobilization of family and community resources in the prevention process. The article concludes with evidence-based recommendations for establishing specialized juvenile judges, integrating social workers into court proceedings, and reforming the terminology used in juvenile proceedings in the Republic of Uzbekistan.