In the U.K., or at least in England, if Bob is convicted of a crime of which Alice is a victim, Bob may be ordered by the court at sentencing to pay to it on Alice’s behalf a sum representing losses and insults to Alice which she suffered as a result of Bob’s crime. This is known as a criminal compensation order.

I’d like to know how widely such mechanisms exist throughout the world, especially the U.S., but also for any jurisdictions that anyone would like to answer for.

3 Answers 3


In the United States, in criminal cases, this is known as a restitution order.

The measure of amounts awarded is narrower than in a civil action. The example of the Colorado law on the topic is discussed here.

It is usually prepared, sometimes with a separate hearing, in parallel to the pre-sentencing and sentencing proceedings, following a conviction.


This is called sentence of reparation.


In it is called la peine de sanction-réparation. (Rough translation: The sentence of the reparation penalty).

The relevant law is article 131-8-1 of the Code pénal. It is also made applicable to non-individual persons (personnes morales) by article 131-39-1.

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