عنوان مقاله [English]
نویسندگان [English]چکیده [English]
Background and objectives: With the increasing use of advanced equipment and facilities by criminals and conversely the use of traditional methods of crime detection by officers, criminal justice system has faced with critical challenges in the modern and organized crime detection. This issue has attracted the attention of some countries in the application of active approaches to deal with these crimes. This study addresses the active approach in process of preliminary investigation in the three countries of Iran, France, and America.
Methodology: In terms of its objectives, the present study is of an applied research type. In term of the nature of the data this study is a qualitative descriptive-analytic research.
Findings and results: The examination showed that in the laws and jurisprudence of Iran, as the case, there are examples of active investigations. However, there is no single idea on active investigations in the criminal laws of Iran. In the criminal laws of France, in most cases, specific mechanisms for doing this type of research has been predicted by the legislator, and while preserving the social security and the need to deal with organized criminals, they protect citizens' rights and liberty. The laws and jurisprudence in America, has accepted resorting to such investigations more widely than the laws and jurisprudence of Iran and France