对于非法证据的处理,美国的排除规则和英国的裁量排除是当今西方国家最具代表性的两种路径。尽管美英两国的搜查、扣押法律同出普通法传统之源,但在非法搜查、扣押等违法获取的证据的采信问题上,立场迥异。路径不同,但命运同归,令人费解的是,两种路 For the treatment of illegal evidence, the exclusionary rules of the United States and the UK’s exclusion of awards are the two most representative routes in Western countries today. Despite the search and seizure laws of the United States and Britain, which have common law sources, they have taken quite different positions in the collection of evidence of unlawful acquisitions and seizures. Different paths, but the same fate, it is puzzling is that two ways