Frontiers of Law in China >

2011 , Vol. 6 >Issue 1: 44 - 97

DOI: https://doi.org/10.1007/s11463-011-0118-4

research-article

Evidence Collection in the German, American and Chinese Legal Systems: A Comparative Analysis

  • Yanrong Zhao
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  • School of Civil, Commercial and Economic Law, China University of Political Science and Law, Beijing 100088, China

Published date: 05 Mar 2011

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2014 Higher Education Press and Thomson Reuters
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Abstract

After comparing different procedures of evidence collection in the German, American and Chinese legal systems, the author analyzes the reasons behind the differences: Each system is determined by its specific social culture and is compatible with the construction of the civil procedures of its own. Based on China’s specific social culture and its system of civil procedure law, the German style of evidence collection is in a better position to provide guidance for China in pursuit of justice.

Key words： evidence collection; legal system; civil procedure

Cite this article

Yanrong Zhao . Evidence Collection in the German, American and Chinese Legal Systems: A Comparative Analysis[J]. Frontiers of Law in China, 2011 , 6(1) : 44 -97 . DOI: 10.1007/s11463-011-0118-4

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