The two nations are similar in their substantive criminal laws, although the range and character of sanctions are more diverse in The Netherlands. In addition, the police forces in both nations are the major agency for controlling input into the criminal justice system. However, the Dutch police can generally only issue cautions for minor traffic offenders, whereas in England it extends in principle to all except motoring offenses. The main distinction between the systems of England and The Netherlands relates to the important role of the public prosecution service in shaping judicial sentencing policy in The Netherlands. The English criminal justice system has no real counterpart to the formidable powers of the Dutch prosecutors. In addition, England uses the accusatorial approach and The Netherlands the inquisitorial procedure in its courts, so that Dutch judges have an active role in the proceedings. Moreover, the probation service in The Netherlands has more scope for influencing policy than does its British counterpart. Its prisons are generally smaller than those in England, with only one inmate per cell and the hospitalized mentally ill offenders not counted as part of the prison population. The role of the public prosecutor in integrating sentencing policy is probably the most distinctive feature of the Dutch system. Appended table and list of prosecutor's guidelines.