In general memory leaks tend to occur more frequently in ‘lower level’ languages…ie, those ‘closer’ to the hardware, like assembler or C.
These are the languages more likely to be used in video games because of the necessity for speed and efficiency.
Modern high level languages usually have some sort of garbage collection built in which reduces (but not eliminates) memory leaks. These tend not to be used for video games as they are generally slower and, perhaps more importantly, can have unpredictable performance. Automatic garbage collection can disrupt a game by kicking in at inopportune times.
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