Abstract
The research paper is based on non-conviction based confiscation system. The system was recently proposed by the European Commission. In general, the paper gives a comparative approach between non-conviction based confiscations and conviction-based confiscation. However, in some nations, non-conviction based confiscation is referred to as Civil Forfeiture. The main aim of conducting this study, therefore, is to have a comparative study of the conviction-based confiscation in Kuwait and non-conviction based confiscation in Australia. The study as well will identify the gaps involved in non-conviction based confiscation that will enhance its adoption or not. The significance of the study, however, ...
