我国的检察系统建立至今,经历了多次反复,使得实务界和理论界均开始积极地反省自身的不足。其中关于检察权的独立性的讨论更是占据了检察系统的半壁江山。但是由于我国法制发展较晚,国外的先进经验对我国起到了不可或缺的作用,也是我们研究的重要方法。笔者正是运用比较法来关注我国检察权的独立性问题,以资参考。 Since the establishment of the procuratorial system in our country so far, it has undergone many iterations, so that both substantive and theoretical circles are beginning to actively reflect on their own deficiencies. Among them, the discussion on the independence of procuratorial power occupied more than half of the procuratorial system. However, due to the late development of the legal system in our country, the advanced experience of foreign countries has played an indispensable role in our country and is also an important method for our study. I just use the comparative law to pay attention to the issue of the independence of procuratorial power in our country.