Administrative-legal and criminal aspects of the prosecutor's office

foreign experience and directions for improvement

Resumo

The purpose of the article is to clarify foreign experience concerning legal regulation of the prosecutor’s office functioning. Main content. In Germany, public prosecutor's offices function at all levels of general courts. The Federal Prosecutor General exercises his powers under the overall direction of the German Minister of Justice. It is noted that the modern French prosecutor's office belongs to the executive branch of government and is subordinate to the Ministry of Justice. Officials of the prosecutor’s office are very close to the judicial corps, as they receive the same training and in the course of their careers often move from prosecutors to judges and vice versa. In Great Britain, there is no public prosecutor’s office or its direct counterpart at all. In the system of state authorities, the Royal Prosecutor’s Office functions as a self-consistent and independent authority, whose activities are coordinated by the Attorney General. Methodology. Based on the comparative legal method of foreign prosecutors' offices, data are provided on their place in the state system, the type of model and main functions, which gives an idea of the role and directions of development of the prosecutor's office in the leading countries of the modern world. Conclusions. It has been concluded that there is no single standard in Europe regarding the model of the prosecutor’s office. The analyzed models of prosecutor’s offices have advantages and disadvantages, but none of them is excluded and neither of the models is preferred.