The Age of Criminal Responsibility in Modern Criminal Law: Co mparative Legal Analysis and Intergenerational Aspects

The article presents the results of a comprehensive comparative legal study of the institution on the age of criminal responsibility in the context of modern challenges associated with intergenerational changes. A multi-level analysis of legal regulation and practice of applying age limits in 12 world legal systems is carried out, including Asian countries (China, Japan, Singapore, South Korea), North America (USA, Canada) and Europe (United Kingdom, Germany, France, Russia, Sweden, Finland). An original methodological framework integrating comparative legal and empirical research methods has been developed. Special attention is paid to the analysis of international standards, including the UN Beijing Rules and the Convention on the Rights of the Child. Based on the research results, a set of scientific recommendations for improving Russian legislation has been developed, taking into account positive foreign experience and modern challenges.