FEATURES OF THE FUNCTIONING OF THE PROSECUTION AUTHORITIES IN FRANCE AND GERMANY AND THE OPTION OF THEIR IMPLEMENTATION IN UKRAINE

The aim of this article is to analyze the experience of the functioning of the prosecutorial institution in Germany and France, and to outline the potential for its implementation in Ukraine.Results.From an organizational and structural perspective, the prosecution service in France is a centralized system.It operates through the Prosecutors General, General Advocates and their deputies at the appellate and cassation courts, as well as the Prosecutors of the Republic and their deputies at courts of major jurisdiction, all of whom have the status of magistrates within the judiciary.The structure of the prosecution service corresponds to that of the court system.The prosecution is viewed as a body safeguarding public interest, which is why some positions, such as Assistant Prosecutor General, are referred to as General Advocates.A notable characteristic of the development of the prosecutorial institution in both France and Germany is that, having initially emerged as an instrument for persecuting opponents of the ruling regime, it has gradually transformed into one of the key mechanisms for upholding the rule of law and public order by assisting the courts in the administration of justice.Conclusions.It is concluded that there exist various models for organizing prosecution authorities across Europe, none of which is ideal.Nevertheless, many modern democratic states have achieved significant results in ensuring the high quality and effective operation of this institution, recognizing it as a key instrument in upholding the rule of law, legality, and public order.Therefore, the experience of countries such as France and Germany deserves special attention in the context of reforming the prosecution system of Ukraine.Specifically, the French model of incorporating the prosecution service into the executive branch-namely the Ministry of Justice-relieves the prosecution of excessive administrative burdens, allowing it to focus solely on legal functions such as criminal prosecution and supporting the judiciary in the administration of justice.In turn, the German model demonstrates a well-structured approach to the training and staffing of prosecution bodies, which enables a reduction in personnel without compromising the quality and efficiency of prosecutorial functions.