THE COMPARATIVE APPROACH TO STUDIES OF PROSECUTORIAL SYSTEMS YIELDS IMPORTANT INSIGHTS INTO THE FUNCTIONING OF PROSECUTORS BY REVEALING ANALOGOUS FEATURES AND UNIQUE CONDITIONS IN DIFFERENT SITUATIONS. A STRUCTURAL AND FUNCTIONAL APPROACH TO THE PROSECUTORIAL ROLE EXAMINES SEVERAL ASPECTS OF PROSECUTORIAL BEHAVIOR INCLUDING THE USE OF PRIVATE OR PUBLIC PROSECUTORS, THE DEGREE OF CENTRALIZATION OF ORGANIZATION, THE INVESTIGATION AND DETECTION OF OFFENSES, AND THE USE OF PLEA NEGOTIATION. NATIONS VARY CONSIDERABLY IN THE EXTENT OF PRIVATE OR PUBLIC PROSECUTIONS. IN THE UNITED STATES, WHERE PUBLIC PROSECUTORS CONTROL THE FUNCTION, THE RANGE OF PROSECUTORIAL TASKS IS VERY LARGE. ENGLAND'S PRIVATE PROSECUTORS HAVE A MUCH MORE RESTRICTED RANGE, AND PERSONS BRINGING PROSECUTIONS MAY BE REQUIRED BY A COURT TO SHOW THE EXTENT AND QUALITY OF THEIR INTEREST IN THE ACTION. THE CHIEF DISTINGUISHING FEATURE OF THE AMERICAN PROSECUTOR COMPARED WITH THE EUROPEAN COUNTERPART IS THAT THE AMERICAN ATTORNEY IS A LOCAL OFFICIAL, RATHER THAN A NATIONAL ONE. IN JAPAN AND THE SOVIET UNION, ALL PROSECUTIONS ARE CONDUCTED BY REPRESENTATIVES OF THE NATIONAL GOVERNMENT. SUCH CENTRALIZATION MAY BE CONSISTENT WITH DEMOCRACY TO THE EXTENT WHICH IT FOSTERS CONSISTENCY AND UNIFORMITY IN THE ADMINISTRATION OF JUSTICE. THE AMERICAN SYSTEM APPEARS TO TOLERATE MORE PLEA BARGAINING THAN DO OTHER SYSTEMS, BUT SUCH NEGOTIATIONS IN OTHER COUNTRIES MAY BE CONCEALED FROM PUBLIC VIEW. THE TEMPTATION IN THE UNITED STATES TO CREATE 'SPECIAL PROSECUTORS' RESEMBLES THE SOVIET USE OF INSPECTORS GENERAL. REFERENCES ARE PROVIDED. (TWK)