PLEADING REQUIREMENTS AND EQUALITY OF PARTICIPANTS OF CRIMINAL PROCEEDING IN CIVIL LAW SYSTEM The article is based on comparative jurisprudence and thus concentrates a ention on speci c initiative activity of the court in German and French criminal procedure. <...> K e y w o r d s: continental model of legal procedure, initiative authorities of the judge, adversary trial, equality of parties, establishment of the issue, approach of legal systems. <...>