A Comparative Study of the Application of the Doctrine of Prosecuting Discretion in Japan, Germany and China
日、德、中三国适用起诉便宜原则之比较

The doctrine of prosecuting discretion is a widely used principle of prosecution in the criminal procedure. Although Japan, Germany and China are all civil law system countries, there are obvious distinctions among these three countries on the intent, limits and restrictive measures in applying the doctrine. A comparative study on the legislative and judicial experience in applying the doctrine in Japan, Germany and China may be helpful toward a perfect discretionary nol pros in China.