Evidence collection in the German, American and Chinese legal systems: A comparative analysis

After comparing different procedures of evidence collection in the German, American and Chinese legal systems, the author analyzes the reasons behind the differences: Each system is determined by its specific social culture and is compatible with the construction of the civil procedures of its own. Based on China’s specific social culture and its system of civil procedure law, the German style of evidence collection is in a better position to provide guidance for China in pursuit of justice.