“零口供”改革是目前司法改革中一个非常醒目的改革,在全国引发了非常热烈的响应。但是,目前的改革却陷入了困境,也面临着民众质疑的目光,该何去何从也到了关键时刻。这其中最主要的原因就是我们的目光只限于沉默权这一点,没有看到与沉默权密切相关的外围制度与配套制度以及它们的功能。西方国家的沉默权制度经历了几百年的发展,已经发展得非常成熟,有很多地方值得我们学习。笔者正是从这点出发,考察西方国家的沉默权与相关制度,希望能对我国目前的相应改革有所助益。 The “zero provision” reform is a very striking reform in the current judicial reform that has triggered a very enthusiastic response across the country. However, the current reform has been in a dilemma and is also facing the question of public opinion. It is also at a crucial moment where to go. The most important reason for this is that our eyes are limited to the right to silence. We have not seen the peripheral systems and supporting systems closely related to the right to silence and their functions. The system of the right to silence in western countries has undergone centuries of development and has developed very well. There are many places worth learning. Starting from this point, the author examines the right of silence and related systems in the western countries, hoping to be helpful to the current corresponding reform in our country.