中外民事强制执行机制比较研究

“执行难”是中国语境下的特有概念。化解“执行难”的法律法规、文献汗牛充栋。“执行难”却一直困扰着人民法院的工作，成为社会关注的难点。本文通过分析域外民事执行机关的设置、职能和性质着手，提出化解我国民事“执行难”的关键在于，将民事执行权赋予司法行政部门。

A Comparative Study of Civil Enforcement Mechanisms Home and Abroad

"Law enforcement difficulty" is a specific term in Chinese context.There are a large number of regulations and documents to solve the problem,but it remains an obsession to the People's Court and becomes a focus of concern.By analyzing the establishment of enforcement organs in foreign countries as well as their function and nature,the thesis concludes that the key to the problem is to endue the judicial administrative organ with civil enforcement authority.