Summary

The process of reforming the Estonian Code of Criminal Procedure was neither based on the model of the continental European criminal procedure nor on that of the Anglo-American one, but rather borrowed elements from several systems.
The article analyses the draft Estonian Code of Criminal Procedure focusing primarily on the provisions of the draft Code, which have been influenced by solutions applied in other countries, such as the Italian, German and, particularly, Anglo-American, Russian and French codes of criminal procedure. The author examines the provisions of the draft Code borrowed from the law of other countries and outlines the specific features present in the Estonian Code.
Further, the author gives an evaluation of the draft Code pointing out that it has achieved a desirable balance between the need of the society for security, on the one hand, and ensuring the general human rights, on the other. The author makes proposals for amending the draft Code, of which some have already been taken into account by the draftsmen.