陪审制最初萌芽于被誉为民主摇篮的古希腊,随后在英国发展成形,并经英国殖民脚步的扩张移植到各个英属殖民地,最终被世界各国所仿效。本文以两大法系颇具代表性的英、美、法、德四个国家为例,浅析陪审制在两大法系的发展历程与现状。 Jury system initially sprouted in the ancient Greece, known as the cradle of democracy, then evolved in England and transplanted to various British colonies after the expansion of British colonial rule and was finally followed by all the countries in the world. This paper takes the four representative countries of Britain, the United States, France and Germany of the two major legal systems as examples to analyze the development course and current situation of jury system in the two legal systems.