عنوان مقاله [English]
Begging as a social phenomenon and behavior. Governments' responses to this phenomenon vary, encompassing a wide range of approaches, from mere criminalization to non-criminalization.
In Article 712 of the Islamic Penal Code (1996), the legislator has considered the absolute commission of this act as a crime. On the other hand, Criminalization, is a process based on rationality and is done by taking into account social realities. Therefore, it is necessary to examine other models to assess the position of the Iranian criminal justice system in the face of this phenomenon. Accordingly, a comparative study of the reaction of sixteen countries to this phenomenon shows that the four countries of Iran, England, Wales and Denmark have absolutely criminalized begging: Eight countries in France, Germany, Scotland, Belgium, Jordan, Singapore, Turkey and Switzerland have criminalized this behavior on the condition that it be disruptive, aggressive and abusive, and that children and vulnerable people are abused, and four countries: Sweden, Norway, Malaysia and Canada have not criminalized or decriminalized this behavior, as the case may be.