【摘要】 由于环境问题的紧迫性 ,各国相继产生了应对环境问题的法律体系。由于各个国家的法律传统、法律文化的差异 ,导致了它们在构建环境法律体系以及环境法学科研究方法上的分立。通过比较分析美国、德国和日本三国环境法发展的不同模式 ,期冀从差异中找差距以构建更为行之有效的环境法律体系。更多还原

【Abstract】 Due to the urgency of environmental problems, new types of law system has been established in most countries. However, the course of their environmental law seems quite different, which result from their difference in train of thought, legal tradition, lawsuit concept, etc, all which are discussed in the article. By and large, to analyse the diverse development model of environmental law of the United States, Germany and Japan which seem the most typical will do good to the perfect environmental law system of our country.更多还原