COMPARATIVE ANALYSIS OF THE CONCEPT OF WITNESS IN RUSSIAN AND GERMAN CRIMINAL PROCEEDINGS

The article analyzes the provisions of the Criminal Procedure Codes in the Russian Federation and the Federal Republic of Germany regulating the legal status of a witness in criminal proceedings. It compares the definitions of the concept "witness" presented in the Russian and German criminal procedural law; it also con- siders the attributes of this concept. It characterizes the scope of persons who cannot act as witnesses in Russian and German criminal proceedings; it describes the reasons for refusing (personal, occupational) to act as a wit- ness, the problem of witnesses' appearance; similarities and differences are revealed. Taking into account com- parative law studies, recommendations are made on the improvement of the Criminal Procedure Code norms in the Russian Federation