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我们把对不同国家或地区的侦查理论与实践状况进行异同分析的行为称之为侦查横向比较研究。开展侦查横向比较研究既是打击刑事犯罪国际合作的需要，更是我国改革开放、融入世界司法潮流的迫切要求。我们认为，各国或地区侦查理论和实践状况与其所属的法系有着重要的联系，本文将重点介绍世界上最主要两大法系──英美法系和大陆法系侦查制度的特点，而在介绍两大法系侦查制度时的着眼点是其最典型代表国家的侦查制度。
We refer to the analysis of similarities and differences between the theory and practice of investigation in different countries or regions as a comparative study of investigation. Carrying out the horizontal comparative study of investigation is not only the need to crack down on international cooperation in criminal activities, but also the urgent requirement of our country’s reform and opening up and its integration into the world judicial trend. In our opinion, the theory and practice of investigation in various countries or regions have an important connection with the legal system to which they belong. This article will focus on the characteristics of the two major legal systems in the world, the Anglo-American legal system and the civil law system. However, The focus of the DFA investigation system is its most typical representative of the country’s investigation system.