THESE DAYS it sometimes seems as if we are commenting on nothing but indictments of government officials. They are coming hot and heavy and at every level of government. But there is something different and special about the indictment returned yesterday against three former high officials of the FBI. It is that regardless of the guilt or innocence of the three men on the charge that was brought against them, the Department of Justice has tried to place responsibility for wrongdoing on the people at the top. There have been too many other episodes in the recent past - some involving criminal conduct, others merely mistakes of judgment - in which subordinates took the rap and the top people went free.

We do not wish to prejudge the case against L. Patrick Gray III, W. Mark Felt and Edward S. Miller. They say they are innocent and the government may be hard put to prove them guilty. That is as it should be. The charge against the three is among the most serious that can be leveled against police officers - deliberate abuse of the power they have been given over the lives of citizens.

Nevertheless, Attorney General Griffin Bell has staked a great deal on this case. He chose to pass over those in the chain of command between the three on top and Special Agent John Kearney, against whom charges were dropped. His insistence on pursuing them directly, rather than going after other, lesser fishes in the process, was among the issues that led to the resignation of several of his investigators last winter. Mr. Bell has taken full responsibility both for the investigation and for the decision on whom to prosecute.

Whether or not the case stands up in court, however, Mr.Bell's decision was a good one. It insists on the accountability of high government officials for their acts, and in the area of police powers, this is undisputable.