海峡两岸刑法中的诬告陷害罪之比较

A Comparative Study on Crime of Malicious Accusation between Both Sides of Taiwan Straight

海峡两岸对于打击诬告陷害犯罪都十分重视,但海峡两岸刑法对于诬告陷害罪的规定则不尽相同,无论是罪名、犯罪构成,还是刑事处罚都有很大的差异。海峡两岸诬告陷害罪的有关规定对于彼此而言都具有参照意义,无论是我国大陆刑法还是台湾地区刑法,都存在进一步完善之处。

Both sides of Taiwan straight all attach importance to fighting against the crime of malicious accusation, but there are some different rules in the criminal laws. It is very different in the accusation, criminal structure and criminal punishment. The relevant regnlations about the crime of malicious accusation in the criminal laws of both sides of Taiwan straight have significant of reference to each other and the two criminals all need to perfect.