Doubts over British Megan's Law

Megan Kanka was raped and murdered by a sex offender

It may not be possible to "transpose" the US system of Megan's Law to the UK, a Home Office minister has said.

Gerry Sutcliffe, visiting New Jersey, said any plans to introduce a similar law in the UK would have to take into account its different "structures".

He has met the parents of Megan Kanka, the seven-year-old whose murder in the US by a neighbour who was a convicted sex offender inspired Megan's Law.

It gives US parents access to details on paedophiles living in their area.

Critics say by moving towards a UK form of Megan's Law, the government would be pandering to media pressure but supporters say it would save children's lives.

Campaigners have long called for a similar law in the UK - sometimes called Sarah's Law after eight-year-old Sarah Payne, who was murdered six years ago by paedophile Roy Whiting.

They said... that the UK will be affected differently from the US, because of the different structures that exist Gerry Sutcliffe

After his meeting on Saturday at the Kankas' Hamilton home, Mr Sutcliffe said the couple did not want "sensationalism around these issues".

He added: "They said, quite rightly, that the UK will be affected differently from the US, because of the different structures that exist.

"You can't simply transpose things across. You have got to look at the context."

He said any changes in the British approach would have to combine three elements.

These were a reinforced multi-agency approach, treatment for offenders where possible and "controlled information within communities so people know what is going on in their communities".

"That would add to public confidence," he said. "We certainly don't want to go back to the situation we had with marches in Portsmouth and vigilantes attacking paediatricians."

He said he was not only looking at the US but would also examine practices from other countries before presenting his proposals to Home Secretary John Reid in the autumn.

Public outcry

Mr Sutcliffe began his US visit earlier this week, talking to lawmakers and experts about how to deal with child sex offenders and how much information the public is entitled to know.

The idea of Megan's Law was ruled out by the government when Jack Straw was home secretary, but Mr Sutcliffe said the visit was not a case of making policy "in response to the tabloids", but was about being "practical".

The News of the World campaigned for Sarah's Law

The huge public outcry that followed Megan's murder by a neighbour 12 years ago in Hamilton spawned a raft of local legislation, which was later adopted in various forms across 50 states.

The law allows public access to some information on the history and whereabouts of some high-risk sex offenders, which supporters say has been a valuable deterrent and an important tool for curbing their activities.

In the UK, the News of the World has run a lengthy campaign to introduce Sarah's Law.

But there have been concerns raised that releasing paedophiles' information could divert attention from other dangerous people, as some children are more at risk from people they know than from strangers.

The Office of the Children's Commissioner has said introducing a similar law could harm children as it would drive offenders "underground".