中西代议机关监督权之比较研究

A contrastive study of the supervision powers of the representative and parliamentary institutions of the eastern and western countries

我国人民代表大会与西方议会作为代议机关在监督权的行使方面具有许多相似之处。但是 ,由于我国与西方各国在国体、政体等方面存在本质区别 ,从而导致了中西代议机关在监督权的行使方面存在一些不同之处。西方议会行使监督权的有益经验对我国人大监督权的增强具有积极的借鉴意义。

Abstract: The People's Congress of China and the western parliaments have much in common in exercising supervision power. However, as there is a big disparity in the state system and form of government between China and western countries, all of these inevitably lead to some differences in performing supervision power for the representative institution. The western parliaments’ supervision function provides a good experience for the People’s Congress of China to enhance its supervision power.