检察制度是一国有关检察机关法律地位、职权范围、机构设置等各种制度的总称。各国检察制度与其政治、经济、法律传统具有不同程度的联系,因此形成了各有特色的检察制度。从比较法的视野对比两大法系检察制度的差异,探讨新时期两大法系检察制度的共同发展趋势,对我国司法体制改革无疑具有一定的借鉴意义。 Prosecutorial system is a general term for various systems in a country concerning the legal status, terms of reference and organization of procuratorial organs. Prosecutorial systems in various countries have different degrees of connection with their political, economic and legal traditions, and thus have formed their own distinctive procuratorial systems. From the perspective of comparative law, this paper compares the differences between procuratorate systems in the two legal systems and explores the common development trend of procuratorial systems in the two legal systems in the new era. It undoubtedly has some reference to the judicial system reform in our country.