Editing Reasonable doubt (section)

==By jurisdiction==

===United Kingdom===
In England and Wales, the modern practice often avoids the phrase “beyond reasonable doubt” in favor of telling jurors they must be “sure” of the defendant’s guilt. This rewording follows appeals court rulings expressing concern that the traditional formula might confuse jurors.<ref>[http://www.bailii.org/ew/cases/EWCA/Crim/2009/2563.html R v Majid] [2009] EWCA Crim 2563</ref> In ''Woolmington v DPP'' (1935), the House of Lords famously declared that there is a “golden thread” running through English criminal law: the burden of proof is on the prosecution at all times.<ref>''[http://www.bailii.org/uk/cases/UKHL/1935/1.html Woolmington v DPP] [1935] UKHL 1 (23 May 1935)''</ref> 

===Canada===
The Supreme Court of Canada has emphasized that jurors should be told the prosecution bears the entire burden and that the doubt must be based on reason and common sense. In ''R. v. Lifchus,'' the Court advised jurors that absolute certainty is not required, only that they be “sure” based on the evidence, and that proof of probable guilt is insufficient.<ref name=Lifchus>{{Cite court
  |litigants = R. v. Lifchus
  |vol = [1997] 3
  |reporter = SCR
  |opinion = 320
  |court = SCC
  |date = 1997
  |url=http://www.canlii.org/en/ca/scc/doc/1997/1997canlii319/1997canlii319.html
 }}</ref> Later cases, such as ''R. v. Starr,'' clarified that “proof beyond a reasonable doubt” lies much closer to absolute certainty than to a balance of probabilities.<ref name=Starr>{{Cite court
  |litigants = R. v. Starr
  |vol = [2000] 2
  |reporter = SCR
  |opinion = 144
  |pinpoint = 242
  |court = SCC
  |date = 2000
  |url=http://canlii.ca/en/ca/scc/doc/2000/2000scc40/2000scc40.html
 }}</ref>

===United States===
In the United States, the notion that an accused must be found guilty “beyond a reasonable doubt” is constitutionally mandated under the Due Process Clause.<ref>In re Winship, 397 U.S. 358, 364 (1970)</ref> Although the Supreme Court has discussed this standard in several decisions, it has resisted providing a strict definition; indeed, it has stated that attempts to define the term often “do not usually result in making it any clearer to the minds of the jury.”<ref>Holland v. United States, 348 U.S. 121, 140 (1954)</ref> Critics argue that juror misunderstanding of what “reasonable doubt” requires contributes to inconsistent outcomes and complicates the fairness of the justice system.<ref name="Pi2020"/>

Many proposals to quantify “beyond a reasonable doubt” draw upon the so-called Blackstonian ratio—for example, equating “It is better that ten guilty persons escape than that one innocent suffer” to a 90% threshold of certainty. However, courts vary substantially in how they refer to or adopt Blackstone’s formulation. Some imply a ratio of 1:5 or 1:10, while others have cited values as high as 1:99, resulting in no single uniform benchmark nationwide. Recent scholarship has attempted to catalogue the implicit level of certainty state-by-state.<ref name="Pi2020"/>

===Other jurisdictions===
Civil law jurisdictions often employ a similar requirement that the judge’s conviction be “intimate” or thorough, although explicit percentages are likewise generally avoided. Japan also uses a high standard of persuasion in criminal cases, influenced by the principle of ''in dubio pro reo'' (when in doubt, rule for the accused), but judges sometimes diverge in how strictly they apply it.<ref name="Goodman2003">Goodman, Carl F., ''Rule of Law in Japan: A Comparative Analysis'' (Kluwer Law International, 2003), pp. 253–54.</ref>