司法改革过程中,执行机构的归属问题形成四种主要观点:设立执行局、成立执行法院、引入执行法官制度与交由行政机关负责。四种模式各有利弊,国外的立法例也各有不同。综合多种情况分析,第四种观点更为可取,进一步具体化就是将执行机构设置在司法行政机关,建立专门、统一的司法行政执行体制。 In the process of judicial reform, the ownership of implementing agencies formed four main points: the establishment of the Executive Board, the establishment of the executive court, the introduction of the executive judge system and the responsibility of the administrative organ. There are advantages and disadvantages in each of the four modes, and there are differences between the legislative cases in other countries. According to the analysis of various situations, the fourth viewpoint is more desirable. To further substantiate it is to set the executive body in the judicial administrative organ and set up a special and unified judicial administrative execution system.