Un palais de justice aux multiples portes » La diversité des réponses pénales (Israël, Italie, France)

The concept of a multi-door courthouse presented by Frank Sander in 1976 combined with the concept of the vanishing trial presented by Marc Galanter in 2004, has transcended the boundaries of the civil trial. These concepts born in United-States, have crossed continents and are today relevant to European jurisdictions. This paper presents the emergence of these concepts, in three jurisdictions : Israel, France, and Italy. Those systems are based on different legal traditions. However, they have turned towards flexible procedures adapted to requirements of efficiency and speed. In Israel, the expansion of plea bargaining and the integration of a multi-door courthouse have replaced the heart of the adversarial system, the criminal trial. In France and Italy, it is the heart of the inquisitorial criminal trial, the instruction, which tends to disappear in favor of the diversification of penal proceedings. Today, these three jurisdictions are encountering similar challenges, especially the tension between efficiency considerations and the place of the human being at the heart of criminal justice