普通法系和大陆法系的诉讼制度中都有专家证言制度,用以解决诉讼中认定案件事实时所遇到的专业技术问题。虽然两种专家证言制度有着共同的目的,但是在具体规则上却有诸多不同。本文拟对普通法系和大陆法系的两个典型代表——美国与法国在民事诉讼中的专家证言制度作一比较,并探讨两者的差别背后所反映的两大法系在诉讼制度、原则和理念方面对专家证言制度的影响及其对中国的启示。 There are expert testimony systems in the common law and civil law litigation system to solve the professional technical problems encountered when the facts of the case are found in the litigation. Although the two expert testimonies have common ends, there are many differences in the specific rules. This article intends to make a comparison between the two typical representatives of the common law system and civil law system, that is, the expert testimony system of the United States and France in civil litigation, and discusses the difference between the two legal systems reflected in the litigation system, And the concept of expert testimony on the system and its implications for China.