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两大法系刑事诉讼制度和理念的差异,形成了大陆法系职权主义下的审问式侦查模式和英美法系当事人主义下的弹劾式侦查模式。本文拟在比较分析审问式侦查模式和弹劾式侦查模式各自特点的基础上对我国的刑事诉讼侦查模式提出完善性建议。
The differences between the criminal lawsuit systems and concepts in the two major legal systems formed the mode of interrogation investigation under the civil law system of civil law and the impeachment mode of investigation under the tributary doctrine of the common law system. Based on the comparative analysis of the respective features of the interrogation and impeachment modes, this paper proposes some suggestions for the investigation of criminal procedure in our country.