IMPLEMENTATION OF PROSECUTORIAL SUPERVISION AND CRIMINAL PROSECUTION AT THE STAGE OF COMPLETION OF THE INVESTIGATION IN THE KYRGYZ REPUBLIC AND THE REPUBLIC OF KAZAKHSTAN

By applying the comparative legal research method, a comparison is made between the legislation of the Kyrgyz Republic and the Republic of Kazakhstan, which defines the legal status of the prosecutor's office and the powers assigned to it to carry out prosecutorial supervision and criminal prosecution. During the study, it is emphasized that the legislation of both countries has similarities in the field of establishing the legal status of the supervisory authority and its powers to implement prosecutorial supervision and criminal prosecution, due to objective circumstances related to the homogeneous conditions of development of national legal systems. The article considers the function of the prosecutor's office to implement prosecutorial supervision and criminal prosecution regarding the approval by the prosecutor of the indictment drawn up by the investigating authorities. According to the results of the study, in order to effectively fulfill the tasks of criminal proceedings, a point of view is put forward on considering the possibility of improving the criminal procedure legislation of the Kyrgyz Republic by borrowing the provisions of the relevant legislation of the Republic of Kazakhstan in terms of regulating the drafting and approval of an indictment by the supervising prosecutor.