I recommend you read the report. The charges were brought solely on the claimed accounting shortfalls with no further evidence that the postmasters and sub-postmasters did anything wrong, not even an attempt to discover where the money had gone or anything resembling forensic accounting that would be required in similar US cases.
In the most shocking case, with Martin Griffiths, there were attempts to hold him responsible for robbery loses he had absolutely nothing to do with:
> On 2 May 2013 a robbery occurred at the Post Office which resulted in a net loss to the Post Office of £38,504.96, which was reduced to £15,845 after some of the money was
recovered. Mr Griffiths was injured during the robbery; he was present in the branch when it occurred. The Post Office Investigator advised the Post Office that Mr Griffiths
was partly to blame for the loss sustained by the Post Office and that he should be held responsible for part of the loss. [1]
Such a claim wouldn't even be colorable in most jurisdictions.
I disagree that anything similar could happen at this scale in the US or France. Individual cases might not be handled perfectly, but this is a systemic miscarriage of justice where at every turn individuals were prosecuted without any evidence of individual wrongdoing. It was believed money was missing, no attempt was made to discover how it went missing, and the post-masters were held responsible without further inquiry. The legal system upheld these non-findings as facts and convicted people based upon them.
[1]: Post Office Horizon IT Inquiry, 3.49
