毋庸置疑,清末“预备立宪”即对日本明治宪政的模仿,其原委,笔者已作专论。在此基础上,通过详细比较模仿与被模仿双方的有关实情,笔者还认为:所谓模仿,是就总体而言;对于具体问题,模仿之中又多有保留。有的且为相当重要之处的保留。弄清这种模仿中的保留,有助于我们对清末“预备立宪”的深入研究和全面认识。 Undoubtedly, in the late Qing Dynasty, “preparatory constitutionalism” was an imitation of Meiji constitutional government in Japan. On this basis, through a detailed comparison between imitation and imitation, the author also holds the view that the so-called imitation is generally speaking, and there are many reservations about specific problems in imitation. Something that is of great importance. To clarify the reservations in this imitation will help us to conduct an in-depth study and comprehensive understanding of “preparatory constitutionalism” in the late Qing Dynasty.