由《欧洲人权公约》第6条第3款d项之规定所形成的对质询问规则,在欧洲人权法院审理“卡瓦贾诉英国”一案之后发生了根本性的变化,即从“唯一或决定性规则”转变为了以“三步审查规则”为内容的“卡瓦贾检验标准”。导致这一变化的原因,不仅源于英国法的影响,也有欧洲人权法院对公正标准的调校以及应对案件激增的考虑。而以该案为主线的考察对我国无疑也有着积极的借鉴意义。 The question of the rules of interrogation formulated by the provisions of article 6, paragraph 3 (d), of the European Convention on Human Rights has undergone fundamental changes since the European Court of Human Rights examined the case of “Kavago v. United Kingdom” “The only or decisive rule” has been changed to the “KaVa test criteria” for “three-step review rules.” The reasons for this change stem not only from the impact of English law, but also from the European Court of Human Rights’s adjustment of fair standards and consideration of the surge in cases. However, the investigation based on the case undoubtedly also has positive reference to our country.