Susan Chapman of Toronto’s Green & Chercover, said judges in Canada are reticent about granting restitution orders, in part because of the historical division between criminal and civil justice. 

“There’s also the practical realty. If someone is getting four years in prison, they’re going to be hard-pressed to pay restitution,” Chapman said. 

Waller cited changes to the French justice system, which give victims standing in criminal cases to seek restitution from the accused. 

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