反致制度作为国际私法中一项重要的法律适用制度,从产生至今一直受到很多争议,然而却并未影响其发展,反而为更多的国家所接受,不难看出,于当今国际私法体系中反致制度有其特殊的价值。本文试通过对关于反致制度的赞成论与反对论的观点之辨析,阐明反致的合理性与不足,论述采纳反致制度的必要性。 As an important system of legal application in private international law, Anti-compromise System has been subject to much controversy since its birth, but it has not affected its development. On the contrary, it has been accepted by more countries. It is not difficult to see that in today’s system of private international law, Anti-government system has its special value. This dissertation attempts to analyze the rationale and inadequacies of Anti-Ch’ing through the analysis of the conception of Pro-theory and Anti-opposition of Anti-Ch’ing system, and discusses the necessity of adopting anti-Ch’ing system.