Common law countries share a growing receptiveness to the use of DNA ud(deoxyribonucleic acid) in criminal investigation and prosecution, with the udformalisation and steady expansion of schemes of DNA collection and udretention. Despite a general consensus regarding the significance and udvalue of genetic material in criminal justice, there is considerable uddivergence in terms of the populations from whom DNA may be collected udand the length of time for which DNA may be retained. This article udtakes a comparative approach by assessing the trajectory of the law udrelating to DNA collection and retention in a range of common law udjurisdictions, and ascertains how aspects of particular countries' laws seek udto resolve common problematic issues that arise concerning human rights, udin particular the rights to bodily integrity, of privacy and the presumption udof innocence. It identifies a common international movement to a risk- udbased approach and concludes that of the comparator jurisdictions the udCanadian model provides the most fitting accommodation for human udrights in DNA database expansion.
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