释明权作为既吸收了职权主义的优点又符合当事人主义宗旨的制度对我国的民事诉讼的改革将大有裨益。笔者从我国本土的法治资源考量,对诉讼模式的改革需伴随一系列制度为基础,对大陆法系和英美法系国家和地区的释明权制度作了充分介绍,并且作了相关评析,对释明权制度的研究提供了一些参考。 The system of interpretation as a system that absorbs both the merit of authoritarianism and the doctrine of party principle will be of great benefit to the reform of civil litigation in our country. Based on the consideration of the resources of the rule of law in our country, the author introduces the system of the right of interpretation in the civil law system and common law countries and regions based on a series of systems, and makes some relevant comments. The study of the system of interpretation of power provides some reference.