Comparative approaches to the regulation of parole: directions for reforming kazakhstan's legislation

This article analyzes the legislation on parole in six jurisdictions—England and Wales, Germany, Spain, the United States, the Republic of Korea, and Kazakhstan—using an analytical matrix comprising seven criteria. Three institutional models for making decisions on parole are identified: the judicial model (including a mandatory advisory subtype, as in Germany and Spain), the commission model, and the administrative model. Based on the data obtained, six legislative recommendations are proposed for reforming Article 72 of the Criminal Code of the Republic of Kazakhstan regarding the procedure for granting