Abstract
Among the achievements of legal modernization that gripped Muslim states during the 19th and 20th century was the introduction of public prosecution in their legal systems. It was a major step towards the creation of modern legal systems in these countries whose legal traditions did not know this legal institute. Its establishment had a dual role: building a stable legal system that would enable the protection of the rights and freedoms of all citizens, but also limit the right to prosecution exclusively to the state, thus eliminating the possibility of further abuses. This paper presents the development of public prosecution in thirteen modern Muslim countries in North Africa, the Middle East and South Asia. They approached the construction of this institute in various ways, and the prosecution, due to various political, legal, cultural and other circumstances, faced and still is exposed to challenges that significantly determine its current and future development.
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