Disclosure of Document in Civil Proceeding

In civil proceeding, plaintiff is require meanwhile access to valid evidence and provide it in the judicial authority, prove his claim. According to the traditional view, plaintiff is required to provide evidence from on behalf of himself and he could not obtained evidence proving claim from another party or third party. But today the view outdated and according to mechanism of disclosure of document, when document as one of the most important evidence, be in control another party or third party, plaintiff can request disclose it in order to prove his claim. The present research aims at a theoretical and comparative study, position of the legal system of Germany, Japan, France, England and Iran explain to the mechanism.