Civil law countries have absorbed the principle of debate, but they are different from common law countries. The main difference is that the judge is not only a "passive arbitrator" like the common law countries, but also directs the whole trial, actively interrogates the litigants, and actively collects the investigation evidence, which is not limited by witnesses and evidence summoned by both parties. French Criminal Procedure Law 1808, German Criminal Procedure Law 1877 and Japanese Criminal Procedure Law 1890 all stipulate this. After the Second World War, Japan completely revised the Criminal Procedure Law in 1948, which introduced the principles and systems of the Anglo-American legal system to a great extent, stipulated that the defendant or criminal suspect can choose a defender at any time, and emphasized the debate between the two parties.
Article 1 18 of the Criminal Procedure Law of People's Republic of China (PRC) stipulates: "After the court investigation is over, the public prosecutor will speak, the victim will speak, and then the defendant will make statements and defend himself, and the defender will defend himself, so they can argue with each other. After the presiding judge announces the end of the debate, the defendant has the right to make a final statement. " However, court debate is not stipulated as the principle of debate.