1.前言亚洲地区的股东代表诉讼(以下简称代表诉讼)对于从事比较公司法研究的学者而言是个有吸引力的课题。代表诉讼起源于美国和英国,它现在已经开始成为亚洲主要经济体的公司法律制度中普遍的特征。的确,代表诉讼已经被亚洲很多地区采纳并且越来越受到这些地区的公司利益相关者、立法机关、法院和学者的重视,这些地区指的是亚洲 1. Preface Shareholder representation litigation in Asia (hereinafter referred to as “representative litigation”) is an attractive topic for academics engaged in comparative corporate law research. The representative lawsuits, which originated in the United States and the United Kingdom, have now begun to become common features of corporate legal systems in Asia’s major economies. Indeed, the lawsuit has been adopted in many parts of Asia and is increasingly valued by corporate stakeholders, legislatures, courts and academics in these regions, which refer to Asia