مكانة النظام العام في القانون الواجب التطبيق على منازعات الميراث

الملخص EN

Many disputes and practical problems arise in matters of inheritance in the domestic law, which is the family law in his third book that includes the provisions of inheritance, not to mention the disputes of international law.

We have selected inheritance as a model for study and research Considering the discrepancy therein in provisions and effects between national law and foreign laws, given that its reference in family law and in all Arab personal status laws is an Islamic jurisprudential reference.

While his reference to foreign countries is based on completely different social and political considerations, and this inevitably results in the difference in public order in these relations, which may sometimes lead to the application of the judge’s law And excluding the application of foreign law that differs from the personal law of the parties in terms of source and provisions.