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从世界范围看,由于各国历史文化和司法观念不同,检警关系大概有两种模式:一种是德、法等大陆法系国家普遍实行的“检警一体”模式,一种是英、美等英美法系国家普遍采用的“检警分离”模式。然而,在检警关系的设置上,不管是检警一体还是检警分离的构架,都要考虑两方面的价值取向:一是力求侦查机关正确地行使侦查权,收集充分的证据,
Judging from the perspective of the world, there are roughly two modes for the relationship between the prosecutors and the police as a result of the different historical and cultural concepts and judicial concepts in each country. One is the model of “prosecutor and police as one” commonly practiced in civil law countries such as Germany and France, , The United States and other common law countries common law “police separation ” mode. However, in setting up the relationship between the police and the police, regardless of whether the combination of the police and the police or the separation of the police and the police, the two values should be taken into consideration: First, the investigation authority should exercise its power of investigation properly and gather sufficient evidence,