Apart from this, taking into consideration of the other aspects, there are two kinds
of plea bargaining, as endorsed in International jurisprudence. i.e., Express and implicit
plea bargaining. Express bargaining occurs when an accused or his lawyer negotiates
directly with a prosecutor or a trial judge concerning the benefits that may follow the
entry of a plea of guilty. Implicit bargaining, on the other hand, occurs without face-to-
face negotiations. In Implicit bargainings, the trial judges especially, establish a pattern
of treating accused who plead guilty more leniently than those who exercise the right to
trial, and the accused therefore come to expect that the entry of guilty pleas will be
rewarded.
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