在国际私法或冲突法的法律和学科体系中,证据冲突一直是国内外国际法学者忽略的领域。主要原因是证据的性质不容易确定:证据是国际法还是国内法,是程序法还是实体法,是公法还是私法,各国学者认识不一。在中国,证据问题一直有国内法学者在研究,但是,他们未能站在冲突法的高度来 In the legal and disciplinary systems of private international law or conflict law, the evidence conflict has always been a neglected area of ​​international law scholars. The main reason is that the nature of the evidence is not easy to determine: whether the evidence is international law or domestic law, procedural law or substantive law, public law or private law, and scholars of different countries have different understandings. In China, evidence issues have been studied by domestic law scholars, but they failed to stand at the height of the law of conflict