从检察制度的历史与比较论我国检察官之定位与保障

改革开放以来，我国与国际社会交流频繁，特别是受美国制度影响，一直有将检察官行政官化的呼声。但是，从检察制度的历史渊源以及各国检察官类型的比较研究可以得知，纯粹行政官化的检察官并不契合我国社会。我国应将检察官定位为司法官，并仿效大陆法系国家，给予其充分的身份保障。

On Position and Safeguards of Prosecutors in History and Comparison of the Prosecution System

Since Reformation and Opening, China has been experiencing more communications to the international community, especially with the US. Therefore there is an argument that the prosecutors of China should be recognized as administrators, learning from the US. However, by analyzing the source and development of prosecution system of main democratic states, it is proved that the prosecutors recognized as administrators do not fit in China. The prosecutors of China should be recognized as legal officials, and the status safeguards should be approved accordingly.