ABSTRACT. Tadic holds that a clear understanding of the meaning and nature of "harmonization" makes it possible to judge the implications of harmonization efforts in relation to other goals and processes in the field of criminal justice. Zaibert writes that, in the continental scheme, justifications are constituted by facts, states of affairs which render a certain behavior which at first sight might appear to violate the norms of a society. Klip observes that uniformity requires a common institutional structure (a common legislator, a common government and a common judiciary)