The purpose of this article is to study the theory and practice of Korean pardon system, to analyse its problems and to suggest some ways of solving or preventing those problems. In this articles, the books, the articles and official statistics on the korean and such european countries as Germany, France, Italy and Greece are studied and compared each other. The contents of this article is as follows. The first chapter is an introduction. The second chapter is about the history of pardon and the korean pardon system. In the third chapter, the practice of general pardon and special pardon from 1948 to present in Korea and its problems studied. The fourth chapter is a comparative study on korean pardon system with some european countries such as Germany, France, Italy and Greece. In the fifth chapter, some ways of controlling and limiting the pardon power of the president are suggested. The sixth chapter is a conclusion.

赦免에 관한 比較法的 硏究
  Ⅰ. 서론
  Ⅱ. 사면제도의 역사와 내용
  Ⅲ. 사면의 실태 및 문제점
  Ⅳ. 유럽국가에서의 사면에 대한 통제방안
  Ⅴ. 사면의 통제 및 개선방안
  Ⅵ. 결어
  참고문헌
  ABSTRACT

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