一、国内外沉默权制度的综述沉默权,虽是一个我们耳熟能详的词语,但这种权利对于我们来说,仍属于一种观念上的权利,还未属于制度上的权利。大体上来说,沉默权有广义和狭义两种解释。广义上讲,沉默权是公民言论自由的具体表现,即任何人有权决定他愿意说什么或不愿意说什么,除非法律另有规定。因此面对其他人或机构的提问,均有权拒绝回答,更有权拒绝回答可能使他自 I. Overview of the System of Right to Silence at Home and Abroad The Right to Silence is a well-known term in our country. However, this right is still an ideological right for us and not yet a system right. In general, there are two broad and narrow interpretations of the right to silence. In a broad sense, the right to silence is a concrete manifestation of the freedom of speech of citizens, that is, anyone has the right to decide what he is willing or unwilling to say unless otherwise provided by law. Therefore, in the face of questions raised by other people or organizations, they all have the right to refuse to answer and to refuse to answer questions