What's Gone Wrong? How other countries deal with young criminals

GERMANY: The country faces what many see as a breakdown in law and order following unity in 1990. In the east especially, where the crime rate was very low during 40 years of totalitarian rule, there has been an explosion of violence. But there has also been a longer term increase in crime which more than doubled in the Sixties and Seventies.

The legal age of criminal responsibility is 14. Children under that age are sent into care or to special schools, where the emphasis is on therapy rather than punishment. Even above 14, the 'juvenile penal institutions' emphasise therapy not punishment.

FRANCE: Anyone of any age can be charged with anything, and magistrates and the social services decide what action is needed (a four-year-old was recently charged with sexual assault in a case widely mocked by the press).

Sanctions against young offenders vary from surveillance under parents' control; placing with a guardian or foster parents; education, re-education or care; or judicial protection, that is, in Young Detainees' Centres within prisons for prisoners under 20 (10.8 per cent of the French jail population is under 21). The minimum age for prison is 13 and there are currently 38 detainees under 16. A 10- year-old convicted of murder could not go to prison.

AUSTRALIA: Crime has increased in most categories over the past 20 years. Reported crimes rose by almost two-thirds between 1980 and 1990. Violent crime increased by about 60 per cent between each of the years 1973, 1980, 1985 and 1990. The peak age of arrest for theft and burglary is 15, and for violent crime 18.

The legal age of criminal responsibility is 10. Adult courts would deal with offenders over 17. Convicted juveniles can be sent to adult prisons, but this is rare. In 1991 there were four offenders aged 16 in adult prisons. There were 884 in juvenile institutions. A 10-year-old suspected of murder would most likely be held in a secure juvenile institution pending a court hearing.

ITALY: Juvenile crime remained steady at 20,000-22,000 cases a year until 1986; between then and 1991 it has more than doubled. Drug offences have tripled. Crimes by children under 14 have risen from 2,500 to 9,500 cases. Reasons include the increase of crimes to finance drug-taking and an increase in the number of minors used by organised crime.

Children under 14 cannot be punished, but can be put in an institution for protection and education, or, if a danger to society, into a reformatory. Those aged 14-18 can be tried as adults but courts are directed to avoid imprisonment as far as possible and only about 1 per cent of criminal minors end up in jail. Parents have a civil responsibility towards the victims of their children's crimes and may have to pay damages.