从现代各国的体制看,检察官一般归属于政府系统,然而,确定检察官是单纯的行政官员的国家很少,普遍认可检察官具有双重的属性,只是不同国家具有不同的倾向性。有的国家倾向于检察权是司法权,检察官是司法官,如德国、意大利;有的则倾向于是行政权和行政官,如美国;日本的检察制度 In modern countries, the public prosecutors usually belong to the government system. However, few countries determine the public prosecutors as pure administrative officials. They generally recognize that prosecutors have double attributes but different nationalities have different tendencies. Some countries tend to procuratorial power is the judicial power, the prosecutor is a judge, such as Germany, Italy; others tend to be administrative and administrative officials, such as the United States; Japan’s prosecution system