LIU Mei.china University of Ploitical Science and Law,100088.

  【Abstract】 Owing to the relationship between laws of Hong Kong and British legal history, the modification of British Hearsay Rule is one of the reasons for Hong Kong to amend its law. For the Hearsay Rule, only the civil proceedings of Hong Kong law have been revised greatly while the Hearsay Rule in criminal proceedings is inherited and is still relatively stringent. In Macao law provisions similar to the Hearsay Rule is closer to the Principle of Direct Trial and Verbal of civil law system. In addition, the statement for future memos system of Macao Criminal Procedure Law is full of distinctive features. Taiwan stipulated the Hearsay Rule while modifying the criminal procedure law in 2003, but the evaluation and dispute between Taiwan scholars on existing law and whether the Hearsay Rule should be adopted are impressive. The legislation of Hong Kong, Macao and Taiwan on the Hearsay Rule and similar provisions is of self-evident referential significance for related legislation in Mainland China.

  【Key words】 Hearsay, Hearsay evidence, Hearsay rule, Witness