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一、空间、服饰和举止二、陪审团遴选程序三、庭审调查程序的不同之处四、法庭证据规则的宽严五、法官的总结和评论证据权六、差异形成的原因目次英美两国正式的陪审团刑事审判在整体上呈现出与法、德等大陆法系国家刑事审判不同的构造和运作方式,这主要体现在两者有着以下共同特征:二分式的法庭和二步式的庭审,以审查控方案件是否成立作为审判的焦点,控辩双方在审判中的主导性地位,严格区分控方案件和辩方案件,以交叉询问作为调查案件事实的主要手段等。
First, the space, clothing and manners Second, the jury selection process Third, the difference between the court trial and investigation procedures Fourth, the court disciplinary rules of evidence Fifth, the judge’s summary and commentary The right of evidence Sixth, the reasons for the difference The formal Anglo-American formal The criminal trial of jury generally shows different structure and operation modes from those of civil law countries such as France and Germany. This is mainly reflected in the following two common characteristics: the dichotomous court and the two-stage trial, To examine the prosecution case is established as the focus of the trial, both prosecutors and defendants in the trial of the dominant position, strictly distinguish between the prosecution case and the defense case, cross-examination as the main means of investigation of the facts of the case.