THE TWO PRELIMINARY INQUIRIES ARE WHETHER THE VICTIM HAS ANY LEGAL RIGHT AT ALL TO RESTITUTION OR DAMAGES FROM THE OFFENDER AND, IF SO, TO WHAT OFFENSES THE RIGHT APPLIES. EACH LEGAL SYSTEM IS THEN EXAMINED TO DETERMINE WHAT TYPE OF COURT WOULD HAVE JURISDICTION TO ENTERTAIN SUCH CLAIMS AND TO ESTABLISH THE ESSENTIAL POINTS OF THAT COURT'S PROCEDURE. THE INQUIRY CONSIDERS WHETHER THE CONCEPT OF RESTITUTION OR DAMAGES HAS BEEN INVOLVED WITH THE PENAL ELEMENT IN ANY LEGAL SYSTEM. IN ADDITION THE FINANCIAL STATUS OF PRISONERS IN DIFFERENT COUNTRIES IS DISCUSSED ON THE HYPOTHESIS THAT RECOURSE MAY EVENTUALLY BE HAD TO THE EARNINGS OF OFFENDERS IN PRISON. INCLUDED ARE SOME GENERAL IMPRESSIONS AS TO HOW RESTITUTION WORKS IN PRACTICE AND WHETHER ANY TREND TO IMPROVE OR TO MODIFY THE PRESENT PROVISIONS CAN BE SEEN IN ANY LEGAL SYSTEM. THE THREE COUNTRIES WHOSE SYSTEMS ARE MOST EMPHASIZED ARE NEW ZEALAND, THE UNITED KINGDOM AND THE UNITED STATES.