近代以来,由于国际间交往的增加,国际民商事流转日益频繁,具有涉外因素的国际民商事案件越来越多,其中许多案件需要到国外调取证据方能有效推进诉讼程序或保证诉讼取得公正结果。这种调查通常在条约或互惠的基础上进行。然而由于各国法律制度 Since the modern era, due to the increase of international exchanges, the circulation of international civil and commercial affairs has become increasingly frequent. There are more and more international civil and commercial cases involving foreign elements. Many of these cases require obtaining evidence from abroad so as to effectively promote the proceedings or ensure the fairness of the litigation result. Such surveys are usually based on treaties or reciprocity. However, due to the legal system of various countries