该文针对行政诉讼诉讼责任的三种流行观点进行评述 ,认为行政诉讼举证责任并不静止地属于某一方。行政诉讼举证责任由多项因素决定 ,随诉讼程序抗辩过程的不同情境而转移 ,举证责任应具体细化 ,使其有可操作的量度。 This article reviews three popular views on the litigation responsibility of administrative litigation and argues that the burden of proof in administrative litigation does not belong to one of the parties statically. The burden of proof in administrative litigation is determined by a number of factors and shifted with different situations in the litigation procedure defenses. The burden of proof should be detailed and made operational.