This study is part of a larger comparative project in which both authors have been involved for a number of years. Its real origins, however, lie in our fascination with the relationship between different legal cultures and criminal law and procedure. As always when faced with trying to understand foreign law and coming to terms with the intricacies of an alien and often unarticulated legal culture, we would never have managed without the help of native lawyers. We are extremely grateful to the English defence advocates, prosecutors, judges and academics who were prepared to speak to us, let us listen to their lectures and sit in their courtrooms. A special word of thanks to Arwel Jones of the Crown Prosecution Service, head of the Law and Procedure Unit at the CPS Strategy and Policy Directorate, for once again not only receiving us but patiently answering our e-mails and putting us right on a number of points. Any mistakes and misunderstandings are, of course, entirely our own.