The Disappearing Trial example, impose further costs on the criminal justice system, due to the increased capacity to prosecute high volumes of cases and unforeseen changes to sentencing. Budgets for government agencies with authority over trial procedures (for example, Ministries of Justice) are often separate from those involving sentenced prisoners (for example, Ministries of Prisons and Correctional Services), which can make tracking the full impact of trial waiver systems difficult. 63. For example, a resource assessment from the Sentencing Council of England and Wales (the Sentencing Council) considered that a change in policy designed to encourage earlier guilty pleas might result in an additional cost of £20 million (under what is termed the “optimistic scenario”) to £50 million (under the “pessimistic scenario”) due to a potential increase in the number of prison places required. The Sentencing Council was unable to quantify the potential savings in costs due to reductions in length of the procedure.79 Similarly, while a slight reduction in the rate of pre-trial detention in Colombia could be detected following the adoption of a trial waiver system (known as “reconocimiento de culpabilidad”), growth in the population of convicted prisoners cast into doubt whether cost savings as such were achieved.80 Mass prosecutions and minor offences 64.  Some trial waiver systems, particularly those which take the form of abbreviated trials or other summary proceedings, are designed primarily to deal with minor crimes. This is evidenced by the fact that in many countries, trial waivers are limited to offences carrying certain maximum sentences (for example, less than six years in the Argentine system). The use of trial waivers to deal specifically with minor crimes is usually related to efficiency goals. 65. However, it is not always clear that these goals are being achieved depending on the indicator of efficiency used. This is because an increase in the ease of processing minor cases allows for a greater number of such prosecutions. More minor cases may therefore proceed to conviction with trial waivers where they may otherwise have been dropped by prosecutors, or the form of trial waiver system adopted may promote overcharging by prosecutors, as noted in the US. ii. Trial waiver systems introduced as part of larger reforms to criminal procedure codes 66. It is relatively common for trial waiver systems to be introduced together with a package of reforms in an overhaul of an entire criminal procedural code, in postconflict countries, in transitions to democracy, and as part of movements from inquisitorial to adversarial systems. This is the case, for example, for many countries in Latin America81 (e.g. Chile, Argentina, Colombia, and Mexico), in the Western Balkans (e.g. Macedonia, Serbia, and Bosnia and Herzegovina), as well as in South Africa. Several EU jurisdictions have also recently adopted various forms of trial waiver systems as part of a move to include more adversarial practices such as oral trials. For example, Italy crafted its system of patteggiamento as part of a new Criminal Procedure Code which came into force in 1989 and which adopted certain elements of adversarialism inspired by the US legal system, justified by both efficiency and due process considerations.82 Romania too included a trial waiver system (known as “recognition of guilt”) in its new Criminal Procedure Code adopted in 2014, and the respondent to our survey explicitly noted the influence of the US model on this process. 67. In these situations, the introduction of trial waiver systems is part of a larger ideological and political project with a number of aims and changes to procedure made at once or as part of one legislative motivation. These reforms are generally associated with a legal system that is more democratic, transparent, and inclusive, with better access to justice for victims and defendants alike.83 In situations in which trial waiver systems are adopted as part of larger reforms, it can sometimes be difficult to identify the precise justification for such systems themselves as a discrete aspect of new criminal codes and practices. This complexity can also make it difficult to determine whether or not trial waiver systems are indeed functioning as intended. 79. “Consultation Stage Resource Assessment: Reduction in Sentence for a Guilty Plea”, the Sentencing Council, paras. 4.1–4.9. Available at: https://www. sentencingcouncil.org.uk/wp-content/uploads/Consultation-Resource-Assessment-Reduction-in-sentence-for-a-guilty-plea.pdf. 80. Zorro, A., “The Impact of Adversarial Criminal Justice in the Prison Population: Evidence from the Colombian Case” (June 26, 2015). Available at: https://ssrn.com/ abstract=2623741; or http://dx.doi.org/10.2139/ssrn.2623741. 81. Langer, M., “Revolution in Latin American Criminal Procedure: Diffusion of Legal Ideas from the Periphery”, American Journal of Comparative Law, Vol. 55, No. 4 (Fall 2007), pp. 662-665, highlighting the work of regional activists and experts in promoting comprehensive reforms to criminal procedure. Available at: http://live. v1.udesa.edu.ar/files/UA_Derecho/SGD%202013/Lange-Revolutionin-Latin-American-Criminal-Procedure.pdf. 82. Langer, “From Legal Transplants to Legal Translations”, supra at n. 8, p. 60. 83. See, e.g., DeShazo, P. and Vargas, J. E., “Judicial Reform in Latin America: An Assessment”, Center for Strategic and International Studies, Policy Papers on the Americas, Vol. XVII, Study 2 (Sept. 2006). Available at: http://siteresources.worldbank.org/INTLAWJUSTINST/Resources/0609_latin_judicial_reform.pdf. 37.