我国当前迫切需要加强制定外国刑事判决的承认与执行法律制度的国内立法,这就必须首先确定其立法模式。本文主张在一般法中主要是先在刑法中规定对外国刑事判决的有条件的积极承认态度,然后在刑事诉讼法中进行程序调整,待条件成熟时,再与专项特别法模式相结合来调整外国刑事判决的承认与执行问题。 There is an urgent need for our country to step up the domestic legislation on the recognition and enforcement of the legal system for the formulation of foreign criminal judgments, which must first determine its legislative model. This paper argues that in the general law, the conditional and positive recognition of foreign criminal decisions should be stipulated in the criminal law first, and then the procedural adjustments should be made in the criminal procedural law. When the conditions are ripe, the law may be combined with the special lex specialis model Recognition and enforcement of foreign criminal judgments.