ABSTRACT
Unlike the inquisitorial models examined above, which were the direct inheritors of the medieval European tradition of bureaucratic justice, the Chinese version had its origins in completely different and much more ancient juridical practices. What is surprising is that, despite this separate ancestry, the two models of inquisitoriality display many similar characteristics. The main difference, however, is that unlike European inquisitoriality which, for the last two centuries, has been threatened by the incursions of adversariality, Chinese authoritarian justice has, throughout this period, faced only the challenge of popular justice.
