THE COMPARISON TOUCHES ON THE ROLE OF THE PUBLIC PROSECUTOR, THE COURT STRUCTURE, PROSECUTORIAL PROCEDURES, PROSECUTORIAL DISCRETION, AND SUPPORTIVE INSTITUTIONS IN NORWAY, DENMARK, THE NETHERLANDS, AND SCOTLAND. PARTICULAR ATTENTION IS DIRECTED TO THE DISCRETIONARY POWERS OF PROSECUTORS, THE PLACE OF PROSECUTORS IN JUDICIAL SYSTEMS, AND THE RELATION OF PROSECUTORS TO POLICE . AN OVERVIEW OF PROSECUTORIAL PRACTICES IN ENGLAND AND WALES IS ALSO PRESENTED, WITH REFERENCE TO CONTROVERSY SURROUNDING THE ROLE OF THE POLICE IN INITIATING AND CARRYING OUT PROSECUTIONS. SUGGESTIONS FOR REPLACING THE ENGLISH SYSTEM WITH ONE SIMILAR TO THAT USED IN SCOTLAND ARE CONSIDERED. IN SCOTLAND, THE PROSECUTORIAL FUNCTION HAS BEEN TAKEN OVER BY FULL-TIME CIVIL SERVANTS, CALLED PROCURATORS-FISCAL, WHO ARE COMPLETELY INDEPENDENT OF THE JUDICIARY AND THE POLICE. THE FEASIBILITY OF INTRODUCING A PROCURATOR-FISCAL SYSTEM IN NEW ZEALAND, WHERE PRIVATE PRACTITIONERS ARE APPOINTED TO SERVE AS PROSECUTORS, IS ALSO CONSIDERED. A BIBLIOGRAPHY IS INCLUDED. (LKM)