The United States and Pakistan were selected as comparison countries, because
the United States was the earliest country to implement Plea Bargaining,
implemented many Plea Bargaining in its criminal justice system and had many
studies on Plea Bargaining and in U.S., most of the suspects chose the plea
bargaining mechanism, while Pakistan was chosen as a comparison because it is a
country that has implemented Plea Bargaining in the criminal justice system,
Pakistan arranged the plea bargaining in solving problems of corruption as an
effort to solving problems of corruption and recovering state financial losses so
Pakistan can optimize the return of state financial losses.
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