| In order to carry out the criminal procedure, Both China and Korea have establishedthe judging court and adopted the corresponding public prosecution system. However,owing to the differences in land area, population, social environment and historicalbackground for adopting the criminal prosecution systems, there are many differences intheir public prosecution systems functioning as a pivot of criminal procedure. However,both in China and in Korea, the public prosecution system is established and operated forthe same purpose. Thus, in order to meet the purpose of the public prosecution system andraise its efficiency in operation, in this paper, we discuss and make a comprehensivecomparison in the nature, organizational system, personnel management, financialbudgetary system, relationship between the prosecutor and the police, the procurator' powerin enforcement measures, registration and investigation, his jurisdiction in examination ofprosecution and instituting a public prosecution, in judgment and other areas.The paper has nine chapters altogether: Chapter One History of ProcuratorialWork. When China amended its law comprehensively at the end of the Qing dynasty, itestablished its public prosecution system according to the conditions of China and withreference to the good parts of foreign public prosecution systems. The procuratorial organthen was the "Bureau of Procuratorial Work" and was set in the court of each level, later, itwas changed into the "Prosecutors' Office". In 1927 of the Kuomintang period, all theprosecutors' offices were canceled and the original procurators were put inside the court ofthe same level. After the founding of the People's Republic of China in 1949, the SupremePeople's Procuratorate was established, but during the Cultural Revolution, theprocuratorial organs of all levels were canceled. After the Cultural Revolution, according tothe provisions of the revised draft of the constitution, the people's procuratorate wasestablished again. According to the constitution, procuratorial organs of all levels wereestablished again rapidly, forming the present public prosecution system.The procuratorial system of Korea was established in 1895 in the late Korean periodand was a successor of that of Japan. In 1910, after Japan had occupied Korea, in order toserve its colonial rule, it revised the Japanese public prosecution system a little and appliedit in Korea. After 1945, in the American military government period after recovery of the??Abstractterritory, the American criminal prosecution system was carried out here. But in 1954 whenKorea formulated its law of criminal procedure, although it assimilated the Americansystem in judicatory, it borrowed the law of criminal procedure of the old Japan in its publicprosecution system.Chapter Two Comparison in the Nature of the Procuratorial Organ TheChinese procuratorial organ is an organ of people's democratic dictatorship, an organ oflegal supervision of the state, and should be responsible to the People's Congress andsubmit its working papers to the latter, and is under the supervision of the latter. Theprocuratorial organ is an organ of law supervision of the state, also a judicial body of thestate, parallel to the judicial apparatus.Although the procurator of Korea is a governmental servant, every procuratorperforms his business in the nature of a judicial body as an independent government officialand objective official. Thus, every procuratorial organ is established corresponding to thecourt of every level.Chapter Three Comparison in Organizational Framework, Personnel Systemand Fiscal Budgetary System. There are a four-level system in China: the supremepeople's procuratorate, the high people's procuratorate, the middle people's procuratoratea...
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