修改后的刑事诉讼法实施后,我国刑事审判方式由审问制转为对抗制,而庭审前的证据开示程序在对抗制的庭审方式中具有极其重要的意义和不容忽视的价值。本文通过比较分析英、美两国的证据开示制度,对照我国司法实践在证据开示中的做法,试图指出我国现行证据制度的缺陷,以期建立我国的证据开示制度。 After the implementation of the amended Criminal Procedure Law, the criminal trial method in our country is changed from interrogation system to adversarial system, and the procedure of evidence discovery before trial is of extremely important significance and value that can not be neglected in the adversarial court trial. This article tries to point out the defects of the current evidence system in our country by comparing and analyzing the evidence discovery system of Britain and the United States against the practice of our country’s judicial practice in the discovery of evidence so as to establish the system of evidence discovery in our country.