Germany as the continental lagal system, its withdrawn right established through legal precedents, the withdrawn right have to have the appearance of significant reasons. 德国作为大陆法系的典型国家,其退股权制度却是通过判例法建立起来的,退股权的产生要有重大事由的出现。
Through comparing the adjudicative document system between Anglo-American legal system and continental lagal system, it is found that the origin of law is different. However, most countries come to an agreement that they pay attention to analysis, argumentation, reasoning of adjudicative document. 文章通过比较考察英美法系与大陆法系的裁判文书制度,虽然法的渊源有所不同,但世界各国在注重裁判文书的分析、论证、说理上却基本是趋向一致的。