ABSTRACT
12 Angry Men is a courtroom drama film made in 1957. The film focuses on the discussions and deliberations of a jury in a murder case, exploring the conflicts among the twelve jurors regarding the defendant’s guilt. This process delves deeply into the pursuit of justice and examines prejudices.
I. INTRODUCTION
Directed by Sidney Lumet, 12 Angry Men is regarded as a significant film in the drama genre, meticulously examining how prejudices within the justice system and interpersonal dynamics can lead to societal and personal conflicts1. The film narrates the case of a poor, foreign young man accused of murdering his father, conveyed through the discussions of the twelve jurors, all grounded in the principle of reasonable doubt. In this process, more than just determining the defendant’s guilt or innocence takes place; social and psychological conflicts are also revealed2. 12 Angry Men clearly illustrates how personal prejudices and group interactions influence decision-making processes. The film highlights the human factors within the justice system, provoking thought on the impacts of social injustice and prejudice that violate equality and lead to discrimination3. Released in 1957, 12 Angry Men garnered Academy Award nominations for Best Director (Sidney Lumet) and Best Editing (Robert C. Jones) in 1958. It also won the Grand Jury Prize at the 1957 Cannes Film Festival and the Best Film Award in 1958. Additionally, it was selected as the best film at the 1957 New York Film Critics Circle Awards4.
II. EVALUATION OF THE JUDICIAL PROCESS WITH IN THE FRAMEWORK OF UNIVERSAL LEGAL PRINCIPLES
A. Principle of Equality and Prohibition of Discrimination
One of the fundamental principles of a fair trial is the principle of equality. According to this principle, an individual should be evaluated equally in the judicial process, regardless of their ethnicity, gender, age, or current circumstances5. However, in 12 Angry Men, some jurors develop prejudices against the defendant, citing his poor background and ethnic origin as reasons for their bias. In the film, prejudices are expressed suggesting that the defendant’s limited proficiency in the language and his ethnic background imply a propensity for criminal behavior. This situation highlights the critical importance of the principle of equality in fair trials and illustrates how its neglect can lead to serious problems within the justice system. Equality ensures that all individuals are evaluated impartially; however, the film demonstrates how this principle is violated and how prejudices can significantly affect a fair trial process. The jurors’ decision to declare the defendant guilty occurred without a proper assessment of the evidence related to the crime, as they made assumptions based on a profile that conformed to their prejudices. This situation raises questions about the feasibility of a fair trial and whether true objectivity can ever be achieved in the judicial process. Equality is a principle that requires all individuals to be assessed equally; however, the practicality of this principle is open to debate. People are not socially, economically, or culturally equal; this disparity can complicate the objective administration of justice. Justice is generally defined according to the shared norms and values of society; however, these norms and values can vary significantly across different communities. Therefore, the administration of justice can vary within the framework of these norms and values, and the parameters used are of great significance in the judicial process. The existence of the jury system has historically been adopted to ensure that justice is administered by representatives of the public and that societal values are reflected in judicial processes6. The decisions of jurors reflect the public’s perception of justice and societal values. However, as seen in 12 Angry Men, this system also has some weaknesses. The biases of jurors and their decisions made without sufficient evidence can violate the right to a fair trial and the principles of universal human rights. Therefore, while advocating for the complete abolition of the jury system is not the solution, it is essential to focus on the training and awareness of jurors to ensure a fairer and more impartial judicial process. In today’s world, prejudices still persist and manifest in our social lives. While it may be theoretically possible to develop a worldview that is free of prejudices or completely value-neutral, in practice, achieving this ideal is quite challenging. However, it is important to reduce the effects of prejudices and adopt a more objective approach7. In the field of law, equality and the prohibition of discrimination are guaranteed in international human rights law (such as documents like the Universal Declaration of Human Rights and the European Convention on Human Rights) as well as in the Turkish Constitution and its laws8. The principle of equality is founded on the concept of human dignity. This relationship is explicitly expressed in both international and national legal documents. Article 1 of the Universal Declaration of Human Rights states that all human beings are born free and equal in dignity and rights, thereby emphasizing the direct connection between the principle of equality and human dignity9. From the perspective of legal philosophy, Immanuel Kant argues in his work “Practical Reasoning” that individuals should be evaluated equally and with dignity. (Kant, 1788). This philosophical viewpoint serves as an important reference for understanding how the principle of equality is related to human dignity. Article 10 of our Constitution10 encompasses the principle of equality, which applies to all state organs, including the legislative, executive, and judiciary. This principle is a universal tenet found in many international and national texts. Article 10 of our Constitution states, “Everyone is equal before the law, without discrimination based on language, race, color, gender, political thought, philosophical belief, religion, sect, or similar reasons.” The European Court of Human Rights (ECHR) defines discrimination as treating individuals in similar situations differently without an objective and reasonable justification11. In accordance with Article 14 of the European Convention on Human Rights12 (ECHR), it states, “The enjoyment of the rights and freedoms set forth in this Convention shall be secured without discrimination on any ground such as sex, race, color, language, political or other opinion, national or social origin, association with a national minority, property, birth, or other status.” The jurors’ attitudes in the film, their perspectives, and their issuance of a verdict without questioning the evidence presented were fundamentally rooted in the fact that the defendant fit a profile associated with the crime.
B. Right to a Fair Trial
The right to a fair trial is one of the cornerstones of legal systems, guaranteeing that all individuals are subject to a neutral judicial process and that they receive a sufficient and balanced evaluation regarding their guilt or innocence. 13 The right to a fair trial encompasses the principles of objectivity and equality, which are essential for the administration of justice. Objectivity ensures that an impartial and unbiased evaluation occurs within the judicial process; that is, individuals are assessed solely based on the evidence and the law. Equality guarantees that everyone is treated according to the same standards and equally within the judicial process. These principles are extensively addressed in International Human Rights Law. For instance, the United Nations’ Standards of Fair Trial (2012) and Article 6 of the European Convention on Human Rights guarantee the rights to an impartial judge, equal treatment, and adequate defense (United Nations, 2012; European Court of Human Rights, 1950). These documents clearly outline how the right to a fair trial encompasses the principles of objectivity and equality, as well as how it is protected by international standards14. Initially, there is a strong belief among the jurors that the defendant is guilty. However, some jurors recognize that this belief is based solely on prejudice and assumptions, advocating for a fair trial process.
The core issue in the film is the jurors’ tendency to render a verdict based solely on the prejudices presented by the defendant’s crime profile, without adequately questioning the evidence and the defendant’s defense. This assessment should be examined in terms of its compliance with the principles of objectivity and impartiality required by the right to a fair trial. The jurors conduct this examination from their own perspectives, which can impact their ability to be truly impartial. However, neutrality and accuracy can vary from person to person. Thomas Kuhn’s views on neutrality and objectivity suggest that these concepts do not represent a universal truth15. Objectivity is shaped by social forces. Accepted truths and the behaviors that reflect these truths in social life are determined by social factors. According to Montesquieu in his work L’Esprit du Droit, societies are governed by various factors, including religion, laws, principles of government, historical lessons, morality, and customs. These elements contribute to forming the “General Spirit” of a society16, The fundamental result of varying societal structures influenced by geography is the existence of different truths and legal rules. Legal regulations are shaped according to the needs of societies and are not fixed; therefore, law cannot be classified as a science, as it continuously evolves and renews itself. In 12 Angry Men, the jurors initially attempt to maintain their neutrality. However, their life experiences, personal beliefs, and values lead them to find the foreign young man guilty. Throughout the jury deliberations, it becomes evident that the jurors struggle to detach from the environmental factors that affect them as human beings, making it nearly impossible to adhere fully to the principles of neutrality and objectivity outlined in national and international laws. The jurors’ decisions jeopardized the fair trial process due to biases and incomplete evaluations. Ultimately, the film concludes with the jurors carefully reviewing the evidence and sharing their thoughts, leading to the decision that the defendant is not guilty. During this process, some jurors highlight that evidence can be interpreted in various ways and question why the prosecutor or defense attorney overlooked certain aspects. Another juror points out the defendant’s inadequate financial situation, suggesting that this is why a state-appointed attorney is involved and that such lawyers cannot earn fees in cases where the defendant is socially profiled as guilty. Consequently, they conclude that the attorney did not perform their duties with due diligence. In the end, even adherence to the legal framework did not safeguard the right to a fair trial.
The right to a fair trial is guaranteed in both national and international legislation. Article 36 of our Constitution states17, “Everyone has the right to seek their rights through legal means. It also contains provisions regarding the presumption of innocence and the right to a fair trial.” Article 6 of the European Convention on Human Rights (ECHR) states18, “Everyone is entitled to a fair trial to determine their guilt or innocence. This includes a public hearing conducted fairly and without delay by an independent and impartial tribunal.” In the film, after hours of discussion and an unbiased evaluation process among the twelve jurors—none of whom are law graduates—they conclude that there are questionable aspects in the evidence presented by the prosecution. As a result, they determine that the defendant cannot be found guilty based on this evidence. This process reveals that the defendant was not judged in accordance with the right to a fair trial.
III. PRINCIPLE OF BENEFITOF THE DOUBT AND EVALUATION OF EVIDENCE
The material purpose of criminal fact-finding, unlike the legal evidence system, necessitates both the freedom to accept everything as evidence and the free evaluation of that evidence19. In criminal proceedings, the judge can base their decision on all types of evidence. The crucial point here is that the evidence used as the basis for the judgment must form the ruling without leaving any room for doubt.
“The fundamental condition for convicting a defendant of a crime is that the crime must be proven beyond any reasonable doubt. Events and claims that are questionable or not fully clarified cannot be interpreted against the defendant to establish a conviction. Criminal conviction must be based on definite and clear evidence, not on any possibility. This proof should not rely on selective evidence while ignoring other pieces, but rather must be definitive and clear, leaving no room for doubt or ambiguity. Convicting a defendant based on even a high probability would mean rendering a judgment without achieving the primary goal of criminal proceedings: to uncover the truth” (Criminal General Assembly - K.2015/35)20
During the jurors’ examination of the evidence, the difficulty in finding the type of knife used in the murder of the defendant’s father is discussed. The discovery of the knife, considered almost unique for its type in 1957 when the film was made, did not provide the necessary certainty for the judgment. As the film progresses and the same knife is found, doubts arise among the jurors. In a criminal trial where there is uncertainty, the principle of “in dubio pro reo” applies, meaning that any doubt should benefit the defendant.
Another piece of evidence is the claim of an elderly man who states that he heard certain conversations and saw the killer leaving the house. As the jurors examine this evidence, it becomes apparent that people’s words and perceptions can vary. They consider the possibility that the elderly man did not consciously provide this information, and that this evidence does not constitute definitive proof of the defendant’s guilt, thereby creating a questionable situation.
The final piece of evidence examined by the jurors is the testimony of a woman who claims to have witnessed the murder. A crucial point is that, by the end of the film, it is revealed that the woman wears glasses, raising doubts among the jurors about her ability to see the incident clearly. This potential inability to accurately perceive the event creates further uncertainty in their deliberations.
The principle of “The Defendant Benefits From The Doubt.”stipulates that a defendant can only be convicted if their guilt is proven beyond any doubt, with clear, credible, and lawful evidence. This ensures that the standard for conviction is high, protecting the rights of the accused by requiring that any uncertainty benefits the defendant21. As a result of the jurors’ evaluation, they concluded that the evidence presented by the prosecution included doubts about the possibility of eyewitness errors. Consequently, the jurors determined that the defendant was not guilty and that a conviction could not be based on this evidence22.
IV. CONCLUSION
The film “12 Angry Men” serves as a profound examination of the quest for justice and the impact of personal biases on court proceedings, highlighting the importance of the fundamental principles of the judicial system and the law23. The trial process depicted in the film highlights the critical importance of the principle of equality and the right to a fair trial, as well as the potential dangers of violating these rights. The film demonstrates that the principle of “in doubt, the defendant benefits” is one of the cornerstones of the law and that a fair trial can only be achieved by adhering to this principle. The jurors’ ability to evaluate the evidence impartially allows them to reach a definitive and clear opinion on the defendant’s guilt or innocence24. It is emphasized that justice cannot be achieved when evidence is not adequately evaluated and when decisions are made based on biases25. The protection of the right to a fair trial is a fundamental requirement for all individuals in accordance with universal principles of law, demonstrating that social prejudices and personal perspectives can impede the pursuit of justice. In this context, the film serves as an important lesson in achieving harmony between legal and social norms.
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FOOTNOTE
1 Micro Destek Yarının Teknolojileri, 12 Angry Men Amerikan Hukuk Sistemi, Access Date: 12.08.2024 https://microdestek.com.tr/12-angry-men-amerikan-hukuk-sistemi.html.
2 Hayal Perdesi, Önyargılar ve 12 Kızgın Adam, Erişim Tarihi: 12.08.2024 https://www.hayalperdesi.net/sinefil/25-onyargilar-ve-12-kizgin-adam. aspx
3 Hayal Perdesi, Önyargılar ve 12 Kızgın Adam, Access Date: 20.08.2024 https://www.hayalperdesi.net/sinefil/25-onyargilar-ve-12-kizgin-adam. aspx.
4 MUBİ, Ödüller ve Festivaller 12 Öfkeli Adam, Access Date: 12.08.2024 https://mubi.com/tr/films/12-angrymen/awards.
5 Türkiye İnsan Hakları Eşitlik Kurumu, Ayrımcılıkla Mücadele ve Eşitlik, Access Date: 12.08.2024 https://www.tihek. gov.tr/kategori/pages/Ayrimcilikla-Mucadele-ve-Esitlik.
6 Hukuk Ansiklopedisi, Jüri Sistemi, Access Date: 22.08.2024 https://hukukbook.com/juri-sistemi/.
7 Habib Balcı, ORAU, Ben, Siz, Onlar ve Önyargılarınız Access Date: 22.08.2024 https://kaynakbaltas.com/ yonetici-lider/ben-siz-onlar-ve-onyargilariniz/.
8 Cansu Koç Başar, Avrupa İnsan Hakları Sözleşmesi Bağlamında Ayrımcılık Yasağı ve Eşitlik İlkesinin Etkin Korunması Üzerine Bir Değerlendirme, Access Date: 12.08.2024 https://dergipark.org.tr/tr/download/ article-file/3366914.
9 İnsan Hakları Evrensel Bildirgesi, Access Date: 22.08.2024 https://www. ihd.org.tr/insan-haklari-evrensel-beyannames/.
10 Türkiye Cumhuriyeti Anayasası m.10, Yayımlandığı Gazete Tarihi 09.11.1982, 17863 sayılı Resmi Gazete (RG).
11 Türkiye İnsan Kaynakları ve Eşitlik Kurumu, “Ayrımcılıkla Mücadele ve Eşitlik”, Access Date: 11.08.2024 https:// www.tihek.gov.tr/kategori/pages/ Ayrimcilikla-Mucadele-ve-Esitlik.
12 Avrupa İnsan Hakları Sözleşmesi m.14, 01.07.2010 tarihli, https://www. yargitay.gov.tr/documents/AIHM.pdf.
13 Council of Europe Avrupa İnsan Hakları Sözleşmesini Etkileri, Adil Yargılanma Hakkı, Access Date: 12.08.2024 https://www.coe.int/tr/web/ impact-convention-human-rights/rightto-a-fair-trial#:~:text=Bir%20birey%20 bir%20c%C3%BCr%C3%BCmle%20 su%C3%A7land%C4%B1%C4%9F%C4%B1nda,a%C3%A7%C4%B1k%20 olarak%20g%C3%B6r%C3%BClmesi%20anlam%C4%B1na%20gelir.
14 Zafer Gören, Genel Eşitlik İlkesi, Access Date: 12.08.2024 https:// dergipark.org.tr/tr/download/article-file/373753.
15 Michael Zerella/ Thomas Kuhn, Paradigma Değişimleri ve Akademik Çatlaklar, Access Date: 22.08.2024 https://onculanalitikfelsefe.com/thomas-kuhn-paradigma-degisimleri-ve-akademik-catlaklar-michael-zerella/.
16 Hüsamettin Uğur, Kanunların Ruhu veya Ruhunu Arayan Kanunlar, Access Date: 22.08.2024 https://www. jurix.com.tr/article/282?u=0&c=0#:~:-text=Montesquieu%20ve%20 Kanunlar%C4%B1n%20 Ruhu,-Montesquieu’ya%20 g%C3%B6re&text=Hukukun%20(kanunlar%C4%B1n)%20toplumdan%20-topluma%20de%C4%9Fi%C5%9Fti%C4%9Fini,d%C4%B1%C5%9F%20 ko%C5%9Fullar%C4%B1n%20rol%20oynad%C4%B1%C4%9F%C4%B1n%C4%B1%20belirtir.
17 Türkiye Cumhuriyeti Anayasası m.36, Yayımlandığı Gazete Tarihi 09.11.1982, 17863 sayılı Resmi Gazete (RG).
18 Avrupa İnsan Hakları Sözleşmesi m.6, 01.07.2010 tarihli, https://www. yargitay.gov.tr/documents/AIHM.pdf.
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