Models of “Bargain Justice” in Criminal Proceedings in Foreign Countries

Based on a comparative analysis of the criminal and criminal procedure legislation of foreign countries, case law, domestic and foreign doctrinal sources, the article substantiates that “bargain justice” has gone beyond the contours of its “original” interpretation solely as a “plea bargaining”, the criteria of which should correspond as closely as possible with the “classic” model plea bargaining. Having become a “societal” institution of criminal justice, “bargain justice” integrates multivariate models of alternative settlement of criminal law conflicts, the content of is filled with a set of elements, such plea bargaining, as well as modernized institutions, in particular, “therapeutic jurisprudence”.The purpose of the study is to identify paternalistic models of “bargain justice” and predictive institutions of alternative justice in the jurisdictions of foreign states. Setting this goal led to the inclusion in the issue of the study conducting a comparative analysis of the legislation of foreign countries and implementing on this basis the differentiation of models of “bargain justice”, the understanding of which is based on the resolution of law conflicts through the conclusion of a “plea bargaining” (agreement) upon the fact of the committed crime, within the framework of which the offender, in exchange for certain “discount”, agrees to plea (or not dispute) his guilt and fulfill other terms of the agreement.The research methodology was the dialectical method of cognition, general scientific methods of abstraction, analysis and synthesis, comparison and generalization, as well as special science methods (comparative, tectological, etc.).The results of the study. The paper attempts to differentiate the pluralism of “bargain justice” models of foreign justice, into transversal groups: 1)nbsp;the classic “plea bargaining” (in the criminal process of United Kingdom and the USA), which became the “cradle” for “conversion” (France, Belgium) and “incentive” (Belarus and Kazakhstan) models of “procedural cooperation agreements”; 2)nbsp;predictive institutions — “therapeutic justice” and “Problem‑Solving Courts” (PSC) as an alternative to criminal prosecution (developing in the US jurisdiction today).