C O M P A R AT I V E S T U D Y whom. A certain fact, which is relevant for rendering a decision, must be established in an appropriate way, free of admixtures of arbitrariness. The facts in the criminal procedure are either proven or unproven and the options are and must be within the domain: proven – unproven, and it is unacceptable to refer to the so-called principle in dubio pro reo, which our law does not even know, and which, objectively, is a line of least resistance and escaping from difficulties of argumentation when they arise. During the XIX century, the Napoleonic model spread throughout Europe, and somewhat survived until mid XX and early XXI century. It, for example, stayed in Italy until 1988, when the new Law on Criminal Procedure244 adopted a system which was mostly adversarial. The same reform towards more adversarial criminal procedure took place later in Germany, most of the Balkan countries and wider. Gazzetta Ufficiale n.250 del 24-10-1988 - Suppl. Ordinario n. 92, http://www.gazzettaufficiale.it/ anteprima/codici/penale (last accessed 21 December 2016). The text published online is the current consolidated version, including all the modifications from the amendments published to date).   244 51