我国当前的公安机关刑事初查呈现出标准不统一、以初查代替侦查、滥用职权、侵犯人权等等不规范现象,究其原因,是制度的缺失。为构建理性化的公安机关刑事初查制度,寻找最适合我国的改革路径,在本文当中,笔者选取域外五个国家的警察初查行为进行探究,以期日后可以起到“他山之石,可以攻玉”的功效。 The current preliminary investigation of public security organs in our country shows that the standard is not uniform, and the initial investigation is used to replace non-standardities such as investigation, abuse of power, and human rights abuses. The reason is that the system lacks. In order to build a rational preliminary system of criminal investigation of public security organs and to find the most suitable reform path for our country, in this paper, the author selects the police investigation behavior of five countries outside the territory for exploration, Can attack jade "effect.