Comparative Analysis of Criminal Regulations Related to Artificial Intelligence and Autonomous Vehicles: A Study of the Legal Systems of Singapore, France and Iran

Document Type : Academicm and Research

Authors

1 Prof. at the Faculty of Law, National University of Malaysia (UKM), Selangor, Malaysia.

2 M.A. in Private Law, Lahijan Branch, Islamic Azad University, Lahijan, Gilan, Iran.

3 Assistant Professor of Law Department, Lahijan Branch, Islamic Azad University, lahijan, Iran.

4 Associate Professor of Law, Ilam. Iran

10.22091/csiw.2025.12231.2630

Abstract

With the rapid advancement of artificial intelligence-based technologies, particularly autonomous vehicles, criminal justice systems are facing novel challenges in identifying and attributing criminal liability. The significance of this issue lies in the fact that, despite their high potential to enhance transportation safety and improve social welfare, autonomous vehicles—due to their reliance on complex algorithms, the absence of direct human control, and the ability to make independent decisions—are transforming the traditional foundations of criminal liability, such as mens rea, foreseeability, and imputability. Addressing this issue is essential in light of the need to reconsider traditional criminal law frameworks and to develop new models that remain effective in confronting emerging technologies.This study aims to conduct a comparative analysis of the legal approaches adopted by France, Singapore, and Iran, examining the capacity of each to regulate criminal liability arising from the malfunction or wrongful behavior of autonomous vehicles. The research employs a descriptive-analytical method based on library resources and legal documents. The findings indicate that, despite philosophical and structural differences among the examined models, each strives to establish clear boundaries between liability and immunity by introducing new frameworks suited to the demands of the AI era. Accordingly, the development of training and licensing systems for technology users, along with the design of empirical testing mechanisms prior to the release of such technologies into real-world settings, are among the key recommendations proposed to enhance criminal accountability in the age of artificial intelligence.

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References

Islamic Penal Code of Iran (2013), Article 117.
Islamic Penal Code of Iran (2013), Article 214.
Islamic Penal Code of Iran (2013), Article 215.
Civil Liability Act of Iran (1960), Article 1.
Civil Liability Act of Iran (1960), Article 10.
Civil Liability Act of Iran (1960), Article 101.
Farzami, R. (2022). Criminal liability arising from driverless vehicles with a focus on artificial intelligence. The 4th International Conference on Interdisciplinary Studies in Management and Engineering.
Yekrangi, M, & Barzegar, M. R. (2022). Criminal liability of the manufacturer and designer of autonomous vehicles for the injuries caused by them. Criminal Law and Criminology Studies, 52(1), 123-148.
 
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