And in France specifically, the first case you open is guaranteed to not be a good item. So it's essentially the same system but with an additional $2,50 entry fee
It's "technically" just, after all.
Edit: I said 'UK' where I should have said 'England and Wales'. Scotland and Northern Ireland have their own legal systems, although I believe both have Adversarial systems they are different in some ways. The US system could, however, be seen as a continuation of the English system.
eats baguette