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Thanks for that very interesting and well informed post, Michael. I do not know of any such work as you suggest. It would be an interesting doctoral thesis. One aspect in which they do do better is the representation of the victim who can become ' une partie civile' and be represented, make representations and see the evidence of all the witnesses.

But they do like to control the investigation. If you know of a relevant witness you have to ask the 'judge d'instruction' to interview him. I went and saw an 'interesting' witness and was roundly told off for doing so!