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This article analyses the decision of 17 June 1997 of the Criminal Law Chamber of the Supreme Court which will have a significant influence on Estonian court precedents in bribery cases. The article points out the main conclusions reached in the decision. The court found that, in the interpretation of an action as bribery, the action sought by the bribery need not be specified. Further, the court ruled that there must be a relationship of equivalence between the actor and receiver as known in the German legal theory. This means that there is a common understanding between the actor who offers a bribe and the official who receives the bribe that the reward is offered and received for an action already committed or to be committed. The author examines these principles and more general aspects of bribery based on the currently effective Estonian law and regulation of bribery in other countries such as Germany, Russia and the former Soviet Union.

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