7.11.3 Hybrid Contemporary SystemsFurthermore, it should be kept in mind that the opposition between adversarial and inquisitorial systems can hardly be used to characterize contemporary systems. Several of the historical traits of these systems have now disappeared or have been mitigated. Common law countries have centralized the duty of prosecution on state authorities, and private prosecution remains only a theoretical possibility. In several continental countries, the investigative judge has been abolished, and where he survived, his role is mostly limited to the investigations on the most serious crimes. Nowadays, in most continental countries, the burden of the investigations for the majority of crimes lies on the public prosecutor and the police.
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