证据保全制度是民事诉讼中一项十分重要的制度,它有着保全证据、开示证据、促成案件于诉讼外解决等优势。世界各国无论是在立法上还是学界内,对于证据保全的规定和理解都有一定的差距,研究各国证据保全制度,于我国证据保全制度的完善有着重要的意义。 The system of evidence preservation is a very important system in civil litigation. It has the advantages of preserving evidence, promulgating evidence and facilitating the resolution of cases outside the litigation. All countries in the world, regardless of whether they are in the legislative or academic circles, have a certain gap in the regulation and understanding of evidence preservation. Studying the system of evidence preservation in various countries is of great significance to the improvement of the system of evidence preservation in our country.