In this article, authors will deal with the plea bargain as an institute, starting with comparison of the role and effect of the plea bargain in Continental law and Common law countries. As an example of Common Law system model of this institute, United States of America will be cited as well as some other prominent examples. Regarding models in Civil law countries, an overview is given, due to diverse models of existence or non-existence in continental law countries. The second part of the article will deal with the legal and social effects of focus plea agreement in Serbia, since its introduction in the Serbian legal system in 2009. As a transitional country, and country striving for the membership in the European Union (EU), Serbia has an interesting position as one of the few remaining countries still adjusting its legal system to the EU model. Of particular interest is the shift in the Serbian Criminal Code that introduced many Common Law elements in its Continental Law basis and in the article will be assessed the benefits and setbacks of it. At the end, on the example of plea bargain the importance of appropriate implementation of the common law elements in Continental law systems will be emphasised.
