Introduction
Different countries in the World have varying criminal justice systems that help in keeping and maintaining peace, law and order in their areas of jurisdiction. The system is meant to deter persons from disrupting peace and order by enforcing compliance to the laid down laws of the country. The prescribed punishments range from punitive to rehabilitative depending on the nature of the crime committed. Through such punishments, the criminal justice has powers to control the society through policing which is the first step to attainment of justice through the system. Criminal justice system has three major parts namely: policing which involves investigations into the alleged crime, courts where judgement is done and corrections where the punishment is administered to the offenders.
Hong Kong Criminal Justice System
When an individual/suspect is arrested, the charges are laid to him or her in the magistrates’ court where criminal proceedings may be instituted. Depending on the seriousness of the crime committed, the suspect can be arraigned in a Magistrates’ Court (for minor offences) or a Court of First Instance or District Court in case the crime is more serious. The decision to prosecute a suspect is usually made by the Secretary of Justice or by a lawyer acting on behalf of the secretary (Chan & Ho, 2017) . Before any case proceeds to trial in the Court, the counsel in the prosecutions division does due diligence to marshal and evaluate the evidence for a stronger case. The Magistrates Court deals with indictable and summary offences and the punishment powers are restricted to a fine of not more than $100,000 or a maximum imprisonment of two years in jail (Chan et al. 2017) . The Magistrate makes a decision either by awarding the penalty to the accused or dismisses the case all together.
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The Magistrate might transfer the indictable offense to the District Court which means that the criminal offence will be heard before a judge. If the accused person has committed a serious crime other than rape, murder, and manslaughter, the Judge in the District Court has a jurisdiction to try the suspect and even impose a maximum imprisonment of up to 7 years (Chui & Lo, 2013) . In case the accused person pleads not guilty, the Judge in the District Court sets a trial date when the case will be ready. If the suspect pleads guilty, the judge hears the case and passes judgment on the same day. Sometimes, the Court might order some reports to be presented, which implies that the case is adjourned to another date. In the trial process, the Law permits the accused person to have a lawyer or to act in person to defend themselves. If the services of a private counsel are expensive and beyond the means of the suspect, he might seek legal aid from the state. The final decision on which language to be used in Court is made by the trial judge.
High Court
The High Court of Hong Kong is made up of the Court of First Instance and Court of Appeal with each of the Court categories having a different mandate and own jurisdiction (Chui et al. 2013) . The accused has the right of appeal which is a crucial part of the legal system of Hong Kong because it allows the superior Court to review decisions made by lower Courts.
Court of First Instance
The Court has both original jurisdiction and appellate jurisdiction. Any party in a criminal case determined in the Magistrates’ Court can appeal in the Court of First Instance by filing a Notice of appeal. The accused person tried in a Tribunal can also file an appeal in this Court (In Chui et al. 2016) . A part from appellate jurisdiction, this Court has original jurisdiction to hear cases of serious crimes such as manslaughter, rape, trafficking, murder, commercial fraud and drug trafficking (In Chui et al. 2016) .
Court of Appeal
The suspect tried of criminal or civil offence in a lower Court such as District Court or Court of First Instance, can file an appeal in Court of Appeal within 28 days after sentencing or apply leave to appeal after 28 days have elapsed (Creutzfeldt, 2018) . The clerk of the Court sends an appeal notice to all the parties involved and the appeal judge considers the notice upon which a date for hearing and determination of the appeal is set or the appeal may be thrown away. The three or two justices of the appeal Court may allow or dismiss the appeal.
Court of Final Appeal
This is the highest appellate Court in Hong Kong where the accused person has a right to file an appeal on the judgment made by the High Court on criminal and civil offences. The law requires that determination of such cases be done by Chief Justice, one non-permanent judge and three permanent judges (Thompson, 2018) .
Germany Criminal Justice System
In Germany, the prosecutor has the exclusive responsibility to investigate with police as a subordinate agency. The criminal procedure in the country is based on coded law where the Public Prosecutor (PP) is the one responsible for investigations in case of a felony case. The German police are not allowed to make any arrest unless the suspect is caught in the act or there is difficulty in identifying the suspect. For a suspect to be detained for more than one day, the court must issue a warrant (Thompson, 2018) . In case the public Prosecutor fails to speed up investigations, the Court must order the release of the suspect after six months. After investigations, the regional PP takes the investigation file and determines whether there is sufficient evidence for the case to proceed to Court and if he finds none, the case is dropped.
After the PP ascertains that there is enough evidence for the case to proceed, the indictment bill and investigation file is send to the Regional Court or District Court depending on the value of the dispute for the matter at hand. District Court hears matters of up to EUR 5,000 (Keleman, 2017) . The judge in the District Court carries out investigation by reading the file before commencement of the trial. The law requires prosecution case to be disclosed to the defence counsel. For misdemeanours, a single judge presides over the case while for minor felonies, the Magistrates Court which is composed of one professional judge and two lays determines it. The ruling on punishment or guilt in the Magistrates Court is by majority rule (Keleman, 2017) .
The jurisdiction of the District Court does not allow it to sentence for more than four years, except in cases where juvenile are involved. The PP and the defendant can appeal the decision of the District Court in the Regional Court (“Landgericht”). In “Landgericht”, the judges verifies the facts on procedure and sentencing in order for them to make a decision (Keleman, 2017) . The County Court is the third stage of prosecution and only appeals on matters of law are considered and no evidence is examined. German law protects the defendant from double jeopardy or repeated prosecution. Based on the decision of the judges in the Regional Courts, the accused person and the prosecution can seek redress from the Federal Court of Appeal. However, no appeal be made judgments made in appellate Courts.
Conclusion
Criminal justice systems of Hong Kong and German share some aspects which include a hierarchical Court system and the autonomy of the Court system. However, they differ in others such as use of the jury in Hong Kong whereas in German the Court system doesn’t allow.
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