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德国一直是大陆法系国家的典型,而日本自明治维新后参照法国与德国的司法制度构建了近代日本司法制度的框架,可以说,德国和日本在法律制度上存在一定的渊源关系。二战后,德国和日本都对本国的刑事诉讼制度进行了修改,当今,两国的刑事侦查制度,在侦查主体、侦查步骤、强制措施等方面都存在一定的差异。
Germany has always been a typical continental legal system in Japan. However, since the Meiji Restoration, Japan has established the framework of modern Japanese judicial system with reference to the judicial system of France and Germany. It can be said that there is a certain relationship between Germany and Japan in the legal system. After World War II, both Germany and Japan amended their criminal procedure system. Nowadays, there are some differences in the criminal investigation system between the two countries in terms of the subjects of investigation, investigation steps and coercive measures.