موانع تطبيق القانون الأجنبي واجب التطبيق في القانون البحريني : دراسة مقارنة

الملخص EN

It is the prerogative of the national judge to exclude the application of foreign law, which has been referred to as the national attribution rule, in three cases: The first is a case where foreign law, which the national attribution rule refers to as its application, conflicts with the fundamental fundamental interests of the state, known as "public order".

Second, if the circumvention of the national attribution rule by deliberately changing the attribution officer has led to the application of foreign law to the issue in question, which is called “Fraud toward Law”.

The third case is the “theory of national interest”.

We will devote research to each of them, and at the end of the research will be the conclusion that will review the most important findings and recommendations that have been reached.