In modern criminal legislation the possession of drugs intended for supply is, without exception, a very serious crime. However, although the possession of drugs for personal use is a oﬀence in most countries, it is a minor oﬀence often punishable by a ﬁne. In Turkey, the sentence of imprisonment of 2–5 years for the possession of drugs for personal use was prescribed in 2014 (Akgul and Murat, 2017, p. 70). Undoubtedly, it is very important to determine whether a person was found in possession of drugs intended for supply or personal use. The role of the courts in determining the purpose of drug possession is highly complex, because it implies getting inside the mind of the oﬀender (Walsh, 2008, p. 479). A comparative analysis of criminal legislation illustrates two concepts of determining intent to supply drugs (Zuﬀa, 2011, p. 1). This paper considers both concepts in detail and determines their ad- vantages and disadvantages. The paper seeks to contribute to a universal consensus on drug policy, which currently does not exist (Akgul and Murat, 2017, p. 65).
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