证人证言是刑事案件公正审判中非常重要的证据,但是现实中却存在着证人出庭难的司法难题。深究其原因,证人出庭难正是因为证人保护制度的缺失。本文首先立足于我国的证人保护现状,通过具体介绍美、英、德、法四国的证人保护先进立法规定和司法操作,提出了符合我国国情的证人保护制度。 Witness testimony is a very important evidence in the fair trial of criminal cases, but in reality, there is a judicial problem that witnesses appear difficult. Deep down to its causes, it is precisely because witnesses appear in court because of the lack of witness protection system. Based on the current situation of witness protection in our country, this paper presents the system of witness protection in line with China’s national conditions by specifically introducing the advanced legislative provisions and judicial operations of witness protection in the United States, Britain, Germany and France.