There are only few problems as to hearsay rule in civil law countries. This is because the legal system in those countries seems to be inquistorial system which imposes upon the court a duty to search for all existing evidence in order to establish fact of the case without the so-called " exclusionary rules "
Thus, hearsay evidence is usually admissible although the question about weight of such evidence still remains.
In the common law countries, in which accusatorial system is adopted, on the other hand , the court has to act as an umpire extracting facts from evidence submitted by each party. Consequently, it becomes essential in this legal system to have a set of rule called " exclusionary rules " specifying which types of evidence are inadmissible. Rule against hearsay is, of course, included in such rules. Thai legal system is extra-ordinary. It looks like civil law system in form; the substance and trial procedure, nevertheless seem to be common law system. This uniqueness has, unfortunately, given rise to the very qusetion whether or not the rule against hearsay is recognized in Thai Law.