IANAL, but afaik this depends on whether the legislation is English law or Latin law from origin. Where Latin law is more about the intent and english, and therefore US law, is more about the letter of the law. Perhaps the distinction is along a different axis but this is how I remember.
You are thinking about common law (originated in England) vs civil law (based on Roman law) In both systems intent is very important in criminal cases.
The real difference is between criminal law and contract law. In contract law. In contract law the intention is fixed by the language of the contract document. It matters less if matter if one party didn't intent to violate the contract. It is what it is.
Thank you for clarifying this. Do you have a link to some overview material on the differences between laws in different countries? Is the distinction between criminal and contract law the same in every region?
