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Ⅰ.IntroductionThe contrast between common law and civil law systems of civil justice is often expressed by juxtaposing adversarial and inquisitorial models of procedure.On the conventional understanding of these two models,civil litigation in common law systems then appears as controlled by litigants who present their respectivecases to a passive judge,and its civil law counterpart as controlled by an active judge who conducts an in-quiry into the facts and the law of a dispute.But while these two contrasting models capture many salient
I. Introduction the contrast between common law and civil law systems of civil justice is often expressed by juxtaposing adversarial and inquisitorial models of procedure. Now the conventional understanding of these two models, civil litigation in common law systems then appears as controlled by litigants who present their respectivecases to a passive judge, and its civil law counterpart as controlled by an active judge who conducts an in-quiry into the facts and the law of a dispute. But while these two contrasting models capture many salient