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大陆法系预审法官制度历史深厚,但在两大法系刑事诉讼司法制度不断交流融合的今天,集侦查权与裁判权于一身的预审法官角色也不断分离,向英美国家的侦查法官转变。
The system of pre-trial judge in civil law system has a profound history. However, as the judicial system of criminal procedure in the two legal systems is constantly communicating and converging, the role of pre-trial judge integrating the power of investigation and jurisdiction has been continuously separated from that of the investigating judges in Britain and the United States.