Comparative Analysis of Investigative Bodies in a Three-Tier Criminal Justice Model

Abstract This study develops a theoretical framework for understanding Kazakhstan’s three-tier criminal justice model, emphasizing recent legislative changes and insights from international practices. The primary focus is to examine how investigative bodies operate within this structure, drawing comparisons with similar models in Germany, France, and Italy. Employing methodologies such as statistical analysis, analogy, generalization, and comparative legal and formal legal approaches, the study identifies unique regulatory features across Kazakhstan and European countries, shaped by respective national interests. The three-tier model, encompassing investigative, judicial, and prosecutorial branches, each with distinct functions, offers insights for optimizing Kazakhstan’s criminal justice system. This analysis contributes actionable recommendations for improving Kazakhstan’s investigative processes by aligning with best practices in criminal law systems worldwide, ultimately aiming to enhance procedural efficiency, safeguard human rights, and strengthen the integrity of criminal investigations in Kazakhstan.