Yes, plenty of other countries have jury duty, but the shape it takes varies widely. Some use juries that look much like the American model, others seat ordinary citizens next to professional judges on a single panel, and a handful have done away with juries altogether. Whether a country uses a jury system usually tracks its legal heritage, with common law nations the most likely to keep traditional juries and civil law countries favoring mixed courts.
Countries That Use Traditional Juries
The most familiar jury systems exist in countries whose law descends from English common law. The United States, United Kingdom, Canada, Australia, New Zealand, and Ireland all empanel juries for serious criminal cases. A group of citizens hears the evidence, deliberates in private, and returns a verdict, while the judge rules on legal questions and typically handles sentencing.
Canada runs jury trials with 12 jurors under its Criminal Code, with provisions letting a trial continue with as few as 10 if jurors drop out.1Justice Laws Website. Criminal Code RSC 1985, c. C-46 Hong Kong kept the jury system it inherited from British rule even after returning to Chinese sovereignty, seating seven jurors for serious offences like murder, manslaughter, and armed robbery, or nine if a judge orders it in complex cases.2Hong Kong Judiciary. Jury
A few civil law countries have adopted something close to this model as well. Spain reintroduced jury trials in 1995 after decades without them. Under Spain’s Organic Act 5/1995, nine citizens hear cases involving specific crimes including homicide, threats, bribery, and misappropriation of public funds, with a professional judge presiding but not voting on the verdict.3Ministerio de Justicia. Organic Act 5/1995 on Jury Court Brazil’s constitution guarantees trial by jury for intentional crimes against life, such as murder, and protects the jury’s sovereignty over its verdicts so a judge cannot simply override them. Russia reintroduced juries in 1993 after they were abolished following the Bolshevik Revolution, and defendants in certain serious cases can request a trial before 12 jurors in regional courts.
Mixed Courts: The More Common Model Worldwide
Many countries involve citizens in criminal trials without using a separate jury at all. In a mixed court, lay participants and professional judges sit on the same panel and deliberate together on guilt and sentence. This model dominates continental Europe and has spread to parts of Asia and Latin America.
Germany
Germany had traditional jury trials in the 19th century but replaced them in 1924 with the Schöffen system. Volunteer lay judges sit alongside professional judges and have equal voting rights on both guilt and sentencing. For medium-severity crimes at local courts, two lay judges sit with one professional judge; for serious crimes at regional courts, the panel expands. Serving when called is a legal duty.
France
France uses a mixed court called the cour d’assises for its most serious criminal cases, primarily murders and rapes. Since 1941, lay citizens have deliberated jointly with professional judges on this court rather than separately, deciding guilt and sentence together.
Japan
Japan launched its saiban-in seido system in 2009 after decades without lay participation in trials. In contested cases, six randomly selected citizens sit with three professional judges, deliberate alongside them, and vote on both guilt and sentencing. Japan had a pure jury system from 1928 to 1943 but suspended it during World War II and chose this hybrid approach when citizen participation returned.
South Korea
South Korea introduced its Citizen Participation Trial system in 2007 as part of a push to democratize the judiciary.4Judicial Policy Research Institute. Citizen Participation Trial Jury verdicts in Korea are advisory rather than binding, leaving professional judges with the final say. The scope of the system has been gradually expanding since its launch.
Countries That Moved Away From Juries
Not every country that once had juries kept them. India tried criminal cases before juries under British colonial rule, but confidence in the system eroded after a series of controversial verdicts, including the 1959 trial of naval officer Kawas Nanavati. Jury trials were phased out and officially abolished in 1973. Singapore and Malaysia, both former British colonies, similarly discontinued jury trials in the decades after independence. Germany’s switch to lay judges in 1924 came from a different motive: a belief that lay participants working next to professionals would produce more consistent, legally sound outcomes than a separate citizen panel.
How Jury Mechanics Differ From Country to Country
Even among countries that have juries, the mechanics vary enough to change outcomes. Size is the most obvious difference. The 12-person jury is standard in the United States and Canada, Hong Kong typically uses seven, and Scotland uses 15 jurors for criminal trials, believed to be the largest jury in the world.5Scottish Government. The Not Proven Verdict and Related Reforms: Consultation
Verdict rules diverge even more. In the United States, criminal jury verdicts must be unanimous to convict for any non-petty offence, in both federal and state courts.6Constitution Annotated. Constitution Annotated – Amdt6.4.4.3 Unanimity of the Jury England and Wales take a different approach. A jury must first try for unanimity, but after at least two hours of deliberation the judge can accept a majority verdict. On a standard 12-person jury that means at least 10 agreeing, and on a jury reduced to 10 members at least 9. The foreman must state in open court how many jurors agreed and dissented on any guilty verdict reached by majority.7Legislation.gov.uk. Juries Act 1974 – Section 17 Majority Verdicts Scotland recently moved to require 10 of its 15 jurors for conviction, and it has historically offered three possible verdicts rather than two: guilty, not guilty, and “not proven,” though that third option has been the subject of recent legislative change.8Law Society of Scotland. From Three Verdicts to Two
The kinds of cases juries hear also narrow sharply outside the United States. Most countries reserve juries for serious criminal matters only. The U.S. is unusual in extending the right to civil disputes under the Seventh Amendment. Even the UK, where the jury trial originated, has largely moved away from civil juries.
Why Jury Trials Are Becoming Rare Even Where They Exist
There is a quieter story behind the formal availability of jury trials. In the United States, the overwhelming majority of criminal cases never reach a jury because defendants accept plea bargains. The same pattern has taken hold across other common law countries, including Australia, England and Wales, New Zealand, and Scotland. The jury trial remains a constitutional right in those systems, but exercising it has become the exception.
Several pressures push in that direction. Plea bargaining offers a predictable outcome and usually a lighter sentence than the risk of trial. Court caseloads would be unmanageable if every defendant demanded a jury. Prosecutors hold significant leverage in charging decisions, which shapes the calculus for defendants weighing whether to go to trial.
Mixed-court systems have not seen the same decline, partly because lay participation is built into the trial itself rather than offered as an alternative to a judge-only proceeding. In Germany, lay judges participate as a matter of course in roughly 20% of criminal trials that reach a full hearing. There is no opt-in, no waiver, and no plea bargain that replaces them. Citizen involvement in those systems happens by default rather than remaining a right that few defendants ever use.