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中国与日本两国政治制度不同,两国的检察制度也是特性大于共性。中国检察权体现为法律监督权和司法权,日本检察权体现为一种行政权和司法权。政治制度的不同,使得两国监察权的运行机制也截然不同:中国的法律监督职能体现为监察职能、公诉职能、诉讼监督职能;日本的检察权体现为侦查权和公诉权。
The political systems of China and Japan are different, and the procuratorial system in the two countries is also characterized by greater than commonalities. Prosecutorial power in China is manifested as legal supervision power and judicial power, and Japanese prosecutorial power is embodied as an administrative power and judicial power. The different political systems make the operating mechanism of supervisory power of the two countries also quite different: the legal supervisory functions in China are manifested in the functions of supervision, public prosecution and litigation; the procuratorial power in Japan is embodied in the power of investigation and prosecution.