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Comparative Analysis

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Chapter Summary

This chapter contains a comparative analysis of significant provisions of multilateral treaties and conventions on extradition. One of the objectives has been to provide the texts as accurately as possible with minor changes in style for purposes of greater clarity. For this reason some of the provisions are quoted textually and others are closely paraphrased. The 1981 Inter-American Convention on Extradition (the 1981 OAS Convention), therefore, adopted the system of the penalty of deprivation of liberty for a certain period instead of listing specific offenses. The other multilateral conventions among the American countries, with the exception of two, also establish the system of duration of the penalty as a basis for extradition. The Treaty on Extradition (the 1879 Treaty), in Article 1, enumerated nearly ten extraditable crimes, and added a general rule: crimes should be punishable by a penalty of at least two years of prison.

Keywords: 1981 Inter-American Convention on Extradition; American countries; extradition; multilateral conventions; multilateral treaties

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