The same crime, judged by the world.

Homicide — how 14 countries sentence it

For a clear-cut intentional killing of one adult by another, sentencing across these 14 jurisdictions ranges from a mandatory death sentence to determinate prison terms with single-digit-year minima. Retentionist systems (China, Saudi Arabia, Singapore, India, Japan, South Korea, Taiwan, and many US states) keep the death penalty on the books for murder, though actual use varies enormously: Singapore imposes a MANDATORY death sentence for a killing done with the intention of causing death; Saudi Arabia treats intentional murder as qisas (retaliation, i.e. execution) subject to the victim's heirs' pardon or acceptance of diya (blood money); and China executes actively, often via a suspended 'death with two-year reprieve' that usually commutes to life. By contrast, South Korea and Taiwan retain the penalty but impose it rarely, and South Korea has carried out no executions since 1997 (de facto abolitionist). All the European jurisdictions plus Brazil and Australia have abolished capital punishment for ordinary murder; their sentences range from mandatory life (Germany's Mord, England & Wales) to determinate maxima of roughly 25-30 years (France, Netherlands, Brazil). A key civil-law wrinkle: several systems split 'intentional killing' into a premeditated/aggravated tier (life or the longest determinate term) and a plain-intentional tier (single-digit to ~15-25 year terms), so where a 'clear-cut intentional killing' lands depends on premeditation and statutory aggravators. This is general legal-education information, not legal advice.

Starkest gap: The same clear-cut intentional killing can mean a mandatory death sentence in Singapore (or execution via qisas in Saudi Arabia) yet a determinate prison term with a single-digit-year minimum in Germany (Totschlag, from 5 years), Brazil (from 6 years), or Japan/South Korea (from 5 years) - execution versus a term potentially served within a decade or two, for functionally the same act.

• China: For a serious intentional killing: death (often 'death with a two-year reprieve', which usually commutes to life), life imprisonment, or a fixed term of 10+ years (typically the death penalty). Death penalty is on the books.
• Saudi Arabia: Qisas (retaliation) - i.e. the death penalty - unless the victim's heirs pardon the offender or accept diya (blood money); a discretionary prison term may then apply (typically the death penalty). Death penalty is on the books.
• Singapore: Mandatory death sentence for a killing done with the intention of causing death (Penal Code s300(a) / s302) (typically the death penalty). Death penalty is on the books.
• Australia: Maximum life imprisonment; in practice life or a long determinate sentence with a non-parole period (several states have standard non-parole guideposts around 20-25 years for murder) (typically life imprisonment).
• England & Wales (UK): Mandatory life imprisonment; judge sets a minimum term (tariff) typically around 15-30 years before parole eligibility; whole-life orders for the most serious cases (typically life imprisonment).
• India: Life imprisonment is the norm; death penalty only in the 'rarest of rare' cases (typically life imprisonment). Death penalty is on the books.
• Japan: Roughly 10-20 years or life imprisonment for a single-victim intentional killing; death typically reserved for multiple victims or extreme aggravation (typically life imprisonment). Death penalty is on the books.
• South Korea: Roughly 15 years to life imprisonment; death may be pronounced in extreme cases but is not executed (typically life imprisonment). Death penalty is on the books.
• Taiwan: Roughly 15 years to life imprisonment for a clear-cut single-victim killing; death reserved for the most serious cases under strict due-process safeguards (typically life imprisonment). Death penalty is on the books.
• United States: First-degree murder: life imprisonment (often life without parole) or a long term of years; death possible in retentionist states and the federal system (typically life imprisonment). Death penalty is on the books.
• Brazil: Homicidio doloso simples (intentional homicide): 6-20 years; homicidio qualificado (aggravated): 12-30 years (typically a long prison term).
• France: Meurtre (intentional killing): up to 30 years' criminal imprisonment; assassinat (premeditated / by ambush): life imprisonment (typically a long prison term).
• Germany: Plain intentional killing (Totschlag) 5-15 years; killing with a statutory murder characteristic (Mord) mandatory life imprisonment (parole reviewable after ~15 years) (typically a long prison term).
• Netherlands: Doodslag (intentional non-premeditated killing): up to 25 years; moord (premeditated killing): up to 30 years' determinate imprisonment or life (typically a long prison term).

General legal education, not legal advice. Figures are simplified and were last verified 19–20 July 2026; each is sourced in the interactive view above.