THE GREENING OF THE CRIMINAL LAW IN FOREIGN COUNTRIES
The purpose of this article is a comparative legal analysis of the norms of environmental criminal law in foreign countries. It reveals some idea of whether environmental criminal law in the modern world is based on general principles or there are really serious differences on various issues. From the point of view of possible harmonization and unification in this comparative analysis, we will try to briefly review the main similarities and differences. However, it is not possible to give a mandatory comparative analysis of all detailed environmental legal systems. Thus, the purpose of this comparative analysis is limited: we simply want to show in what respect environmental criminal law in Europe today is based on general principles or whether there are indeed serious differences on various issues.